What Are the AI Challenges in Banking? Views from the FT Global Banking Summit
International banking leaders meeting at the FT Global Banking Summit found common challenges in adopting GenAI and managing its risks

The promise of AI in financial services comes with some big challenges. Two weeks ago I joined a group of leaders from top European and American banks in a roundtable discussion at the FT Global Banking Summit to explore challenges and imperatives around integrating AI, particularly Generative AI, into the highly regulated banking sector.
Key themes included:
- The struggle to move beyond the proof-of-concept stage ("pilotitis")
- The critical need for top-down leadership and cultural transformation
- The establishment of robust yet agile governance frameworks
We agreed that while the potential of AI is transformative, its successful implementation hinges on solving foundational issues related to data quality, risk management, and reimagining business processes rather than simply automating existing ones.
Within the framework of Chatham House rules, here are the key takeaways from our enlightening discussion.
Strategic Imperative: Top-Down Leadership and Cultural Transformation
The group unanimously agreed that successful AI adoption is contingent on strong leadership and a profound cultural shift. This top-down vision is essential to move the organization beyond using AI for simple cost-cutting ("quicker, better, cheaper") and toward reimagining fundamental business processes. The goal is to ask transformative questions, such as using AI to prevent customer complaints from ever arising, rather than just processing them faster. Without this leadership-driven cultural change, data scientists and tech teams would struggle to create impactful solutions.
3 Key Challenges in AI Adoption in Banking
Key Challenge 1: Moving from Proof-of-Concept to Enterprise-Scale Production
A major recurring theme was the difficulty of moving AI initiatives from small-scale pilots to fully operationalized, enterprise-class systems - a phenomenon dubbed "pilotitis” by one participant.
Many firms successfully create proofs-of-concept that demonstrate value for a small group, but struggle with the subsequent steps. The challenges of operationalization include achieving scale, ensuring ultra-low latency and high performance, and integrating the solution into the complex, legacy environments of large banks. Participants agreed that without a clear path to production and a focus on real business outcomes and KPIs, many promising AI projects fail to deliver a meaningful return on investment. The discussion highlighted the need to be selective with pilots and ensure they are tied to a strategic business problem that justifies the significant effort of enterprise-wide deployment.
Key Challenge 2: Data Quality and Foundational Management
The adage "garbage in, garbage out" was cited as a fundamental truth in the AI era. AI is not a magical solution for poor data. Trying to apply advanced AI models to a foundation of "crap data" will only lead to poor outcomes. This has led to a renewed focus on data fundamentals. The discussion underscored that before organizations can fully leverage AI, they must invest in comprehensive data management programs to ensure their data is clean, accessible, and useful.
Key Challenge 3: Governance, Risk, and "Shadow AI"
The risk of “Shadow AI” — employees using unapproved, external AI tools and potentially leaking sensitive corporate data — is a big concern. The availability of powerful consumer-grade AI tools means that if companies don't provide a controlled, in-house alternative, employees will find their own solutions, creating immense risk.
The rollout of powerful tools like Microsoft Copilot can inadvertently expose sensitive information if a company's internal access controls are not perfect. For example, Copilot could surface data from a poorly secured SharePoint site that an employee had access to but was unaware of. We concluded that the answer is not to block technology but to fix the underlying issues, such as strengthening access control policies. This highlights the fact that AI often exacerbates existing risks rather than creating entirely new ones.
Opportunity: Large vs. Small Language Models (LLMs vs. SLMs)
A nuanced technical discussion explored the strategic use of different types of language models. While large language models (LLMs) from major providers offer broad capabilities, there is a growing interest in small language models (SLMs). SLMs are not generalists but are specialized for particular use cases, trained on expert data, and validated by subject matter experts. This specialization leads to a higher degree of trust and accuracy for specific tasks.
AI Governance: The Four Pillars of Responsible AI
AI governance was a hot topic during our meeting. I shared FICO’s model for Responsible AI built on four key pillars:
1. Explainable: Understanding the data and logic behind an AI model's decision. This involves transparency into how the model was trained and what data it relies on.
2. Auditable: The ability to trace and understand the decision-making process. FICO uses blockchain technology to create an immutable, time-stamped history of how a model reached a decision, providing a clear chain of custody for audit purposes.
3. Ethical: Ensuring fairness and mitigating bias in the data used for training. This is directly linked to data quality and the strategic management of data as an asset to prevent discriminatory outcomes.
4. Robust: This pillar covers the operational aspects of the AI system, including its availability, resilience, scalability, and cost-effectiveness. The importance of robustness varies by use case; an internal knowledge management tool has lower requirements than a customer-facing system where downtime could halt business operations.
Balancing Speed vs. Risk
A critical tension identified by several participants is the mismatch between the slow, deliberate pace of traditional bank governance and the rapid, iterative nature of AI development. The key takeaway was that governance must not suffocate opportunity. Organizations that can develop slick, proportionate, and agile governance processes — balancing speed with risk — will be the ones that succeed in the AI race.
Customer Experience and the Human Element
The impact of AI on the customer journey was another key topic, and there is a generational shift in communication preferences. While some older customers prefer talking to a human, younger generations are often more comfortable with text messages or chatbots.
AI is currently being applied heavily in onboarding and KYC processes. However, the group recognized that the technology enables a wide array of new touchpoints. This is why FICO has launched “focused sequence models”, which create a 360-degree motion picture of a customer by incorporating a time-series element, allowing the bank to understand a customer's evolution and guide decision-making, moving beyond static data snapshots.
Future Perspective: The Evolution of AI and Regulation
Looking ahead 7 to 10 years, we speculated on the long-term trajectory of AI and its regulation. Clearly, the industry is still in the very early stages of a massive technological shift. Today’s technology will seem primitive in the near future. And along with the industry, regulators are currently in a learning phase.
One participant suggested that meaningful regulation will only emerge once regulators fully understand the technology. Future regulations might not focus on the models themselves (as with current model risk management rules like SR 11-7) but rather on customer outcomes and impact. In the interim, firms must effectively self-regulate by establishing strong internal governance and ethical frameworks.
I was honored to be part of this discussion, and thank the other roundtable members for their candid views. While each participant brought their own concerns and innovations to the table, it was clear that the challenges are felt across the board. These challenges are driving FICO’s innovation in bringing Responsible AI to market.
How FICO Can Help You Adopt Responsible AI
- Read about FICO® Focused Foundation Model for Financial Services Provides Superior Accuracy in Decisioning and Trust When Deploying GenAI
- Read FICO’s new State of Responsible AI for Financial Services report
- Download FICO's AI Playbook: A Step-by-Step Guide for Achieving Responsible AI
- Explore the analytics capabilities in FICO Platform
Popular Posts
Average U.S. FICO® Score at 716, Indicating Improvement in Consumer Credit Behaviors Despite Pandemic
The FICO Score is a broad-based, independent standard measure of credit risk
Read more
The GSE Data Is Public. Here's What It Shows About Credit Score Modernization.
Independent Milliman analysis of GSE historical data confirms what anyone can now verify directly: FICO® Score 10T is the most predictive score.
Read more
FICO® Score High Achievers: Is Age the Only Factor?
<p>FICO’s latest research on <a href="http://www.fico.com/en/blogs/risk-compliance/us-credit-quality-rising-the-beat-goes-on/" target="_blank">national FICO® Score distribution</a> shows that US credit quality continues to trend upwards, with an increasing number of consumers scoring in the highest scores ranges. Given that, we decided it was time to refresh our study on “<a href="http://www.fico.com/en/blogs/risk-compliance/infographic-what-does-a-high-credit-scorer-look-like/" target="_blank">FICO® Score high achievers</a>,” where we examine the credit behavioural profiles of consumers with higher credit scores.</p> <p>As expected, our latest study showed that older people generally have higher scores, as has been the case in our <a href="http://www.fico.com/en/blogs/risk-compliance/age-before-beauty-credit-worthiness-before-youth/" target="_blank">past research</a>. This is largely because they have trade lines that have been open longer, which leads to higher scores (assuming the trade lines are in good standing and all other things equal). The most credit savvy among you will remember that length of credit history accounts for roughly 15% of the overall <a href="http://www.myfico.com/CreditEducation/WhatsInYourScore.aspx" target="_blank">FICO® Score calculation</a>.</p> <p>But for younger consumers, it isn’t too helpful to say, “just wait until you are 50 years old, and that will fix things!” Thus, I decided to dive deeper with our analysis, including looking at the credit behavioural characteristics of younger consumers with high FICO® Scores.</p> <p>In this analysis, I looked at credit characteristics for the two highest score bands, 750-799 and 800-850, which have about 16% and 23% of the population, respectively. I further broke this down by looking at the characteristics of the youngest 15% in each group, which occurs at age 29 for the 750-799 group and 43 for the 800-850. We used FICO<strong>®</strong> Score 9 for our analysis, and examined typical variables of the categories that go into the make-up of the score.</p> <p><a href="http://www.fico.com/en/blogs/wp-content/uploads/2016/10/FICO-Score-High-Achiever-table.png"><img class="alignnone size-full wp-image-29367" src="http://www.fico.com/en/blogs/wp-content/uploads/2016/10/FICO-Score-High-Achiever-table.png" alt="fico-score-high-achiever-table" width="715" height="747" /></a></p> <p>Since there’s a lot to dissect in this chart, I’ll highlight a few findings that struck me: <ul> <li><strong>Credit history.</strong> Higher scores are undoubtedly associated with a longer time on file. What’s striking is the higher average time on file for the 800+ group, both overall and for revolving accounts (the most common trade line). Clearly, it helps to start credit use early in life – but that’s not the sole determining factor for high scoring. The younger cohorts in both the 800+ and 750-799 groups have time on file medians significantly less than their older counterparts.</li> <li><strong>New credit.</strong> High credit scorers do, in fact, pursue new credit. We see little variation in months since last trade line opening and last inquiry among all groups observed.</li> <li><strong>Pay on time.</strong> As you might expect, the further in the past the delinquency, the higher the score – and that’s <u>if</u> a delinquency ever happened. 95% of the 800+ people and 72% of the 750-799 group have never been delinquent, which is a striking contrast to the 57% for the total population. The percentages for the younger groups are even higher, especially so for the 750-799ers. Collection items are also scarce for these high scorers. While 23% of the national population have collection items greater than $99, the figures are only 0.5% for the 800+ group and 3% for the 750-799 group. It is clear that, in conjunction with starting a credit file early, paying on time is a key trait of the FICO® Score high achiever.</li> <li><strong>Balance and utilization.</strong> Finally, we look at how credit is being used, focusing on revolving product use. (Since most people only have one mortgage or one auto loan, variation in instalment product figures is minimal and driven by payment history, which is near perfect for high scorers, as we’ve seen.) FICO® Score high achievers tend to have more open revolving accounts. While the % active trades and utilization are generally lower, by no means do high scorers avoid the use of credit products. What drives the difference here is the amount of <u>available</u> revolving credit utilized. The 800+ group is roughly 1/4 of the national median, both in total and on their highest utilized card; they also have lower balances and more cards<em>. </em>The 750-799 group is more active and higher utilized, but still only at 2/3 of the national figures. The young 750-799 group compensate with lower revolving balances and, as a result, lower utilization, which is in line with what we see for the 800+ group.</li> <li><strong>Benchmarks.</strong> I’d like to point out that while this study provides good benchmarks of the typical credit traits of the FICO® Score high achiever, individual credit profiles will vary widely. And keep in mind that when we sort groups of consumers as a whole by different behaviours, some results may look superficially odd. For example, the 800+ band has a longer median average open account time (128 months) than average revolving months on file (140 months).</li> </ul> So, what do we conclude? A huge takeaway is that high scorers don’t have too much in the way of serious delinquencies and negative public record data.</p> <p>In most respects, the young 800+ people are like their peer group. They really only differ markedly in their shorter credit history and higher non-mortgage balance, both of which are a function of life stage. Our results show that you don’t have to be a credit product hermit; these high scorers have more credit cards. The takeaway is to start credit activity early and maintain well-managed and moderate usage.</p> <p>In many ways, the young 750-799 people are more interesting because their age profile is much younger. Their credit characteristics differ more from their peer group, particularly in terms of length of credit history. They compensate by having almost pristine credit records and lower balances.</p> <p>Ultimately, 39% of US consumers are FICO® Score high achievers, which they accomplish by following common-sense credit practices. It ain’t rocket science!</p>
Read moreTake the next step
Connect with FICO for answers to all your product and solution questions. Interested in becoming a business partner? Contact us to learn more. We look forward to hearing from you.