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Regulator mapping

Covenant produces evidence; your validators and auditors decide — nothing in this table is a claim of compliance. Verify every citation against the primary texts before relying on this table: the sources below are cited as documented in docs/research-guide.md, and section-level pinpoints are marked TODO until they have been read against the letter.

Context, as documented in the research guide: SR 26-2 (17 Apr 2026) supersedes SR 11-7, ties governance intensity to materiality (materiality = exposure × purpose), expects the inventory to support enterprise-level visibility of concentrations and dependencies, and scopes GenAI/agentic systems out while keeping ML credit models in. The RBI FREE-AI committee report (Aug 2025) surveyed regulated entities using AI and found only ~15% used interpretation tools, ~35% validated for bias, ~18% kept audit logs and ~21% monitored drift; it recommends a board-approved AI policy (Rec 14) and a risk-based AI audit framework (Rec 24), expects AI inventories to be available for supervisory inspection, and expects regulated entities to validate third-party models as rigorously as their own.

The ask Source (as documented) Covenant artefact Status
Model inventory supporting enterprise-level visibility of concentrations and dependencies SR 26-2 (section pinpoint TODO); RBI FREE-AI — AI inventories available for supervisory inspection covenant register / diff / show / list: one content-addressed YAML entry per model version under .covenant/, keyed by SHA-256 of the model artefact, training snapshot and covenants file; history is git log shipped
Governance intensity proportionate to materiality, with the tiering justified rather than asserted SR 26-2 — materiality = exposure × purpose; proportionate governance (section pinpoint TODO) Governance schema requires a materiality tier with a mandatory justification; an empty justification or a typo'd key is rejected with a readable error, not silently accepted shipped
Vendor / third-party models carry validation obligations of their own RBI FREE-AI — regulated entities are expected to validate third-party models as rigorously as their own; SR 26-2 (section pinpoint TODO) Vendor block in the inventory record; every check runs identically against a vendor artefact — a third-party model gets no lighter treatment than an in-house one shipped
Adverse-action reasons must be specific and accurate and reflect the factors actually scored; checklists are insufficient, even for complex algorithms CFPB Circular 2022-03 and the Sept 2023 CFPB guidance Check 1 covenant check reason-codes: declared reasons vs measured SHAP attributions for denied applicants — top-1 agreement and top-k Jaccard against thresholds you set, stratified by score band, with background-sensitivity reported. Covenant reports the disagreement; it does not adjudicate which side is right shipped
Documented behaviour must be conceptually sound: a direction the documentation declares must be one the model actually exhibits (feature-highlighting explanations silently assume monotonicity) Barocas, Selbst & Raghavan (arXiv 1912.04930); Provenir (2022) — constraints before SHAP-based reasons; SR 26-2 conceptual-soundness pinpoint TODO Check 2 covenant check monotonicity: declared vs configured (constraints read off the estimator) vs empirical (dominance pairs + ICE paths), per-feature violation rates against a stated threshold shipped
Declared feature set matches the features the model actually uses Inventory-accuracy framing — SR 26-2 expects the inventory to give enterprise-level visibility of dependencies (as documented in the research guide); the declared-vs-used test itself is Covenant's construction, no section is claimed Check 3 covenant check features: declared vs used features shipped
Excluded variables stay excluded, and their obvious proxies are surfaced The exclusion is the model owner's own documented claim; the association screen follows arXiv 2511.03807 (per the research guide). No regulatory pinpoint is claimed Check 4 covenant check exclusions: measured influence of declared exclusions plus an association screen — proxies are surfaced, not proven absent shipped
Ongoing monitoring and outcome analysis SR 26-2 (section pinpoint TODO); RBI FREE-AI survey — only ~21% of AI-using entities monitored drift covenant report: discrimination, calibration, stability and drift with bootstrap CIs, rendered deterministically and mapped line-by-line to these asks shipped
Drift / stability statistics RBI FREE-AI survey — ~21% monitored drift; SR 26-2 (section pinpoint TODO) PSI/CSI and stability sections of covenant report, computed in-house, deterministic bytes shipped
Audit trail: runs are logged, evidence is citable and replayable RBI FREE-AI survey — only ~18% of AI-using entities kept audit logs Hash-stamped check records (no timestamps in the record body), append-only runs.log per model, and byte-identical replay: identical inputs produce identical, hash-addressed records at the same path shipped
Board-approved AI policy and a risk-based AI audit framework RBI FREE-AI Rec 14 (board-approved AI policy) and Rec 24 (risk-based AI audit framework) Out of scope as a deliverable — a board policy is organisational, and Covenant does not write it. Covenant's records and report are evidence inputs such a policy and audit framework can point at out of scope (evidence inputs only)

Two honesty notes, restated because they govern how this table may be used:

  • A row marked "shipped" means the artefact exists and runs; it never means the ask is satisfied. Passing a check is a rate above a threshold you chose, recorded so a validator can inspect it.
  • The proxy screen in Check 4 surfaces obvious proxies; it does not and cannot prove their absence.