ebir
ES
Committee question

What happens if the AI vendor disappears or defaults?

With the hardware on your site, you already have everything in your company: hardware, model weights, knowledge base, audit log and manuals. The exit plan sets format, deadlines, transition and certified deletion, and it is tested every year. When the hardware is ours, optional escrow of models and code with a third party is available.

The detail

SR 26-2 from the Federal Reserve, OCC and FDIC (April 17, 2026) asks banks for contingency plans for model vendors; the exit plan answers that question. We give notice before any change of base model.

Sources

  • SR 26-2, section VII, April 17, 2026.
  • DEBIR governance framework, commitment 5: clean exit.

Regulatory framework verified against primary sources on November 1, 2026.

Next step

Discovery sessions, no commitment

With technology, compliance and two process owners. Includes an offline demonstration prepared for your sector, without using your company’s data.

1

Inventory and obligations

Data in four levels and a first review of what your sector requires.

2

Three candidate use cases

And the Assessment proposal. The Discovery is credited against the Assessment.

3

Founding clients program

Three seats, with an explicit discount in exchange for a publishable case and a reference.

Terms

Discovery and evidence pilot at no cost, Assessment at a discount, in exchange for a publishable case, a reference and feedback. Continuous operation is always paid at list price.