FREE COMPLIANCE GUIDE

AI and Your Trust Compliance Program

What you need to figure out before your next examination

AI and Compliance Self Assessment Mockup

Is your compliance program keeping pace with AI, or is it a year or two behind a problem that is moving faster than your examination cycle?





    Most trust compliance programs were not built with AI in mind. The gaps tend to show up at the worst possible moment.

    • A staff member has been using a general-purpose AI tool to draft memos and nobody has a policy governing it.
    • A vendor activated an AI feature inside your trust accounting system and compliance was never asked to evaluate it.
    • An examiner asks how AI is governed in your department and there is no documented answer.
    • A fiduciary error occurs and an AI tool was part of the workflow, but the audit trail cannot demonstrate human review.

    Regulators are beginning to ask these questions. The OCC, FDIC, and Federal Reserve have all signaled that AI governance is moving onto their examination agenda.

    What You'll Learn

    This 12-question self-assessment covers the specific areas where trust compliance programs are most commonly unprepared for the AI governance questions regulators are beginning to ask:

    • Whether your department has a written policy governing staff use of AI tools, including tools being used without formal authorization
    • Whether vendor-supplied AI features inside your existing platforms have been identified and evaluated for compliance implications
    • Whether your procedures require documented human review of AI-assisted work product before it is used in fiduciary decisions
    • Whether your compliance testing program has been updated to detect AI-related control weaknesses
    • Whether your risk assessment includes AI adoption as a risk category
    • Whether your board has received any formal briefing on AI governance inside the trust department

    Why Download?

    Jamie Schupp has spent more than 27 years advising banks, trust departments, registered investment advisors, and broker dealers on regulatory, compliance, and legal matters. He has seen how compliance gaps develop before they surface in examinations, and he knows what examiners are beginning to look for as AI becomes part of the daily workflow in trust operations. This assessment is not a vendor comparison or a policy template. It is a diagnostic tool designed to give compliance officers and department heads an honest picture of where their program stands before an examiner provides one for them.

    AI and Compliance Self Assessment Mockup

    Download Your Free Copy

    Work through 12 questions covering AI use policies, vendor-embedded AI, fiduciary documentation, compliance testing, risk assessment, board oversight, and insurance coverage — and find out where your program stands before your next examination.





      About Pohl Consulting & Training

      Pohl Consulting and Training has served trust departments, trust companies, and wealth management organizations since 1975. The firm’s risk and compliance practice works alongside technology, benchmarking, and organizational development — which means we bring a full view of your organization to the conversation, not just a compliance lens.

      Have questions about what you find?

      Schedule a no-obligation conversation with Jamie to discuss your compliance program, talk through specific concerns, or explore whether outside guidance makes sense for your organization.

      Jamie Schupp

      Jamie Schupp, JD

      Director, Risk Management and Compliance

      jschupp@pohlconsulting.com