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The automotive market is entering a new phase defined not just by what consumers are buying, but by how they’re choosing to finance it. According to Experian Automotive’s State of the Automotive Finance Market Report: Q1 2026, nearly one-third (35.55%) of all new vehicle loans now stretch more than six years, up from 30.83% in Q1 2025. Similarly on the used side, 31.54% of loans extended more than six years, an increase from 28.60% last year. The shift highlights why affordability is reshaping how consumers are financing their vehicles, particularly in larger and higher-priced vehicles. Refinancing gains traction as interest rates stabilize In addition to longer-term loans, consumers are becoming increasingly deliberate with their financing decisions and managing monthly payments as refinancing activity has gained momentum. For instance, consumers who refinanced this quarter lowered their interest rate by 2.2% and saved an average of $81 on their monthly payment. Credit unions, in particular, continued to play a major role in helping consumers secure more affordable payment options. In Q1 2025, credit unions accounted for the lion’s share of automotive refinancing at 63.43%, from 62.31% a year ago. By comparison, banks went from 23.51% to 22.59% year-over-year. Furthermore, those who refinanced with a credit union saved an average of $101 this quarter, whereas those who refinanced with banks saved $60. Expanding credit access through flexible financing Another notable trend this quarter was the incessant growth in subprime financing as credit accessibility across the market continues to increase. In the first quarter of this year, subprime borrowers made up 15.75% of total vehicle financing, from 14.40% last year. For new vehicles in particular, the subprime market went from 5.61% to 6.88% year-over-year, while subprime in used vehicle financing grew to 20.60% this quarter, from 19.36% a year ago. Increased activity in the subprime segment highlights continued confidence in the automotive market and underscores the importance of expanded financing options. As consumers seek greater flexibility with financing decisions that fit their lifestyle, lenders and dealers have the opportunity to approach them with more personalized solutions. These trends are helping keep both new and used vehicle markets moving forward, while creating new opportunities for consumers to manage payments and purchase confidently. To learn more about automotive finance trends, view the full State of the Automotive Finance Market Report: Q1 2026 presentation on demand.

Trigger leads have long been the preferred solution for identifying high-intent mortgage borrowers. But with the implementation of the Homebuyers Privacy Protection Act (HPPA), which introduces new limitations and consumer protections around trigger leads, that playbook will need to shift. Now, lenders are quickly facing a pivotal shift in how they discover, engage, and convert prospective borrowers into customers. The industry now stands at a crossroads. Lenders who adapt early—leaning into predictive tools, consent-based engagement, and smarter prescreening—will redefine borrower acquisition in a more privacy-centric era.  HPPA: A structural change to mortgage marketing  The HPPA amends the Fair Credit Reporting Act by significantly restricting the use of mortgage inquiries for prescreen purposes. As of March 5, 2026, credit bureaus may only provide or utilize mortgage inquiries to:  End users with explicit borrower consent  The originator of the consumer’s current mortgage  The servicer of the consumer’s current mortgage  An insured depository institution or credit union where the consumer has an existing account  While these exemptions may provide continuity for banks and credit unions, many mortgage brokers and nonbank lenders will need to overhaul their prescreen practices—or risk being cut off entirely from a previously high-performing acquisition channel.  Why this isn’t just a compliance shift—It’s a strategic recalibration  Mortgage triggers in prescreen allow lenders to react instantly to consumer intent. Lenders rely on a prompt and convincing narrative to entice applicants to switch lenders. Mortgage inquiry triggers are effective and were, therefore, a prospecting strategy for many lenders. Recent legislative changes significantly restrict the availability of these inquiry triggers, and impacted lenders are focusing on a more intentional prospecting strategy to compete.   Without these mortgage triggers in prescreen, lenders need to ask:  Who are we trying to reach?  What early signals can we act on?  How do we earn permission and attention before a mortgage inquiry ever happens?  Transforming the funnel: From reaction to anticipation  The shift in mortgage inquiry-based prescreen isn’t the end of high-intent lead targeting. It’s the beginning of a more strategic and intentional approach—one that leverages earlier indicators of mortgage readiness and focuses on building relationships, not just closing transactions.  Here’s where the momentum is evolving, creating a new and smarter funnel:  Prescreen marketing: Using credit and behavioral attributes to help identify consumers who meet specific lending criteria before they signal active intent.  Predictive modeling: Leveraging propensity scores or custom models to prioritize outreach based on conversion likelihood.  Consent-based engagement: Implementing compliant mechanisms to capture and manage borrower opt-ins at scale.  The power of predictive modeling  According to recent industry interviews, propensity modeling is emerging as one of the most effective replacements for trigger-based prescreen. These models analyze hundreds of credit attributes—such as utilization, account mix, account age, and depth—to help identify consumers statistically more likely to seek a mortgage.  For lenders just beginning to use predictive modeling, off-the-shelf models can be a quick way to identify potential borrowers. For example, when layering propensity scores on top of credit eligibility, which can improve borrower targeting, many lenders see an increase in open mortgage loan rates.  Meanwhile, custom-built models, which analyze a lender’s own campaign performance over time, offer the highest level of precise targeting. These models isolate the attributes most predictive of conversions within a specific product mix—optimizing not just volume, but fit.  Speed without traditional triggers? It’s possible  One of the biggest concerns among lenders is maintaining the speed historically enabled by trigger leads. But that concern may be overblown.  Self-service prescreen platforms now allow marketers to generate qualified lead lists in as little as 24 hours, enabling rapid response during rate drops, competitive shifts, or seasonal demand spikes.   For those new to prescreening, batch campaigns still offer value, especially with analyst support.   Don’t overlook retention  In an era of intense acquisition competition, retention becomes a key differentiator.  Lenders who monitor property status, cash flow, and consumer credit behavior can proactively identify when an existing borrower is likely to list, refinance, or exit. Armed with that intelligence, lenders can re-engage with the borrower at the right moment—sometimes before a competitor is considered or contacted.  This level of behavioral intelligence may soon separate proactive lenders from reactive ones.  Actions instead of reactions  The evolution of trigger-based prescreen doesn’t just require new tools; it demands new thinking. Lenders should begin by auditing their current pipelines and determining:  What percentage of our acquisition is dependent on triggers?  What share of our book falls under the HPPA exemptions?  How will we scale compliant opt-in collection?  Are our current prescreen or modeling capabilities future-ready?  Those who answer these questions today—and act on them—won’t just be in compliance with the new laws, they’ll lead in a transformed market. Lenders should also be asking:   Do we have the infrastructure to collect and act on borrower consent?  Are our acquisition teams equipped to run prescreen campaigns — both batch and self-service?  What predictive models are we using (or could we use) to prioritize leads?  Are we proactively monitoring our portfolio to catch retention risks early?  How are we preparing our sales teams for longer, more consultative buying journeys?  Conclusion  The HPPA signals a shift away from relying on passive, inquiry-based prescreen acquisition and the beginning of smarter, more strategic engagement with potential borrowers. Lenders who embrace this transition early will find themselves not just compliant, but competitive—with deeper borrower insights, better conversion rates, and stronger long-term customer relationships.  The market is moving. The only question is: will you lead the change or chase it?  Citation  Experian. (2025, November). Interview: How the Homebuyers Privacy Protection Act is reshaping mortgage marketing—and what lenders should do now [transcript]. Experian Mortgage Insights. Insights based on lender feedback, campaign performance data, and analysis of prescreen marketing strategies and predictive modeling outcomes were gathered from Experian client engagements and internal mortgage analytics between May and October 2025. Homebuyers Privacy Protection Act timeline and legal context referenced from legislation signed September 5, 2025, with implementation beginning March 5, 2026.   

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Customers rarely announce their departure. Instead, they quietly reduce engagement, move deposits and explore competing offers. By the time attrition shows up in reporting, competitors may have already captured meaningful wallet share. For lenders, the risk isn’t just lost accounts, it’s silent revenue erosion within relationships that still appear intact. The hidden risk in your portfolio Today’s consumers often hold less than half of their deposits or loans with a single provider. At the same time: Competition for prime borrowers continues to intensify. Cross-sell remains one of the most effective and efficient growth strategies available. Even small improvements in retention can drive outsized profitability gains. The opportunity is real, but only if you can see momentum early and act before competitors do. From static reviews to strategic signals Traditional monthly and quarterly reviews confirm what has already happened, but they rarely surface early indicators like emerging behavioral shifts or improving credit capacity. Modern portfolio management requires continuous visibility into behavioral signals, trended credit data and event-based triggers that highlight change as it happens. When you can see momentum forming, you can act with precision, intervene before balances leave, engage customers as capacity strengthens, and activate compliant prescreen cross-sell campaigns at the right moment. Our new interactive strategic snapshot outlines the modern approach to portfolio management, one that connects ongoing account review with timely, event-based signals, helping you protect, retain and grow high-value customers. Download it now to see how to turn early signals into stronger customer lifetime value. Read the snapshot

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Lending hasn’t slowed down—but many decisioning processes have. Applications are coming in faster. Fraud is becoming more sophisticated. Borrowers expect near-instant responses. And yet, inside many organizations, decisions are still being made across fragmented systems, manual reviews, and rigid strategies that weren’t designed and aren’t optimized for today’s environment. That broadening gap isn’t just an operational issue but often stems from a lack of innovation as well. And it’s quietly costing lenders growth, efficiency, and competitive position. When decisioning falls behind, some symptoms are easy to recognize, like applications taking days to process, teams overloaded with manual reviews, and credit and fraud decisions happening in separate platforms. Others are not as obvious, but arguably more impactful, slipping bottom lines and fraud and therefore losses lurking in lenders’ portfolios. The root issue is a fragmented infrastructure. Experian has reported that while 79% of financial institutions surveyed globally want fewer vendors or more unified approaches, they typically use eight or more tools across credit, fraud and compliance. As most decisioning environments cannot integrate data, adapt strategies, and execute decisions in real time, lenders often have to make tradeoffs. Speed vs. accuracy; growth vs. risk; and automation vs. control are just some. Meanwhile, the market has moved on. Leading lenders are no longer optimizing individual steps. They’re rethinking decisioning as a connected, intelligent system. Gaps forming from status quo in 8 key decision areas Across the lending lifecycle, there are eight critical moments where decisioning can either accelerate growth or create friction. Pre-qualification: Pre-qualification should expand your funnel with confidence. But limited data access and static criteria often result in overly conservative targeting or missed opportunities. Additionally, the delay in acting on a pre-qualification funnel highlights a key area for opportunity among many lenders. Instant credit decisions: Customers expect real-time outcomes. When decisions rely on manual intervention or fragmented inputs, speed and conversions suffer. Prescreen and targeting: Disconnected data and rigid segmentation can lead to poorly aligned offers, reducing response rates and wasting acquisition spend. Credit line management: Without dynamic strategies, credit lines may be too restrictive (limiting growth) or too aggressive (increasing risk). Early delinquency management: Missed early signals and delayed interventions make it harder to prevent accounts from deteriorating. Mid- and late-stage delinquency: Strategies that don’t adapt to evolving borrower behavior reduce recovery effectiveness and increase losses. Collections and recovery: Manual, one-size-fits-all approaches limit recovery rates and increase operational cost. Ongoing strategy optimization: Perhaps the most overlooked gap: many lenders lack the ability to continuously test, learn, and refine decision strategies as conditions change. What these gaps are really costing you Individually, each of these breakdowns may seem manageable. Together, they can create systemic drag on performance. That shows up in four critical ways: Missed growth opportunities: Good borrowers are declined, abandoned, or never targeted in the first place. Credit offers fail to align with actual borrower potential. Higher operational costs: Manual reviews and disconnected workflows consume time and resources that could be spent on higher-value work. Increased fraud exposure and friction: Fraud is proliferating and becoming more expensive to manage. The Federal Trade Commission reported $12.5B were lost to fraud in the U.S. in 2024, a 25% increase over the prior year. For many financial institutions, the first reaction is often to add more steps to the decisioning process, which can impact good borrowers. Increased competitive pressure: Fintechs and modern lenders are focused on delivering faster, more personalized experiences, capturing share while traditional processes lag behind. 80% of banks and credit unions plan to increase their technology spending in 2026, yet many continue to fall short on planned system deployments, according to Cornerstone Advisors’ annual “What’s Going On in Banking” research report. What innovative decisioning leaders are doing differently Leading lenders are changing how decisions are made, creating a competitive advantage. Instead of stitching together point solutions, they’re adopting a more integrated approach that brings together: Comprehensive data – including both credit and fraud insights Optimized decision strategies – designed to balance growth and risk Real-time execution – enabling faster, more consistent outcomes Continuous optimization – adapting to changing market conditions Strategic partnerships – leveraging third-party industry expertise to augment their own This shift eliminates the need for tradeoffs and instead allows lenders to increase approvals while maintaining control, reducing manual effort while improving consistency, and responding faster without sacrificing confidence. The stakes are high and the competition for consumers is even higher, particularly against a backdrop of ever-evolving fraud risks, continuously increasing consumer expectations for seamless, digital-first experiences and often limited resources. Nearly half of banks and 59% of credit unions have already deployed generative AI, with more investing now, according to the Cornerstone Advisors’ report. Closing the innovation gap requires a more fundamental shift toward decisioning systems that are connected, scalable, and built for continuous change. A new foundation for decisioning This is where platforms like Experian Decisioning are changing the landscape. By bringing together credit and fraud insights, decision strategies, and a flexible technology architecture, lenders can move beyond fragmented processes and build a more unified, intelligent decisioning approach. One that fits within existing systems but also evolves with your needs. Where to start Impactful change doesn’t need to be an overhaul of everything at once for most organizations. The first step is understanding where your biggest gaps exist, and which decision areas are creating the most friction or missed opportunity. Once you can see where decisioning is not optimized, you can begin to redesign it in a way that’s faster and more adept for what lending has become. By making better decisions, faster, and with greater confidence, lenders can process applications more efficiently and also break away from the pack by leveraging decisioning as a strategic advantage. Learn more

As the market finds its footing, evolving consumer demand is driving changes in new and used vehicle registrations. In response, manufacturers are balancing affordability and production efficiency to protect their market share. According to Experian’s Automotive Market Trends Report: Q4 2025, new vehicle registrations slightly decreased to 3.8 million, from 4 million this time last year. On the used side, registrations ticked up slightly year-over-year, going from 9 million to 9.1 million. With elevated new vehicle pricing and higher interest rates likely playing a role in new vehicle registrations dipping, buyers seem to be gravitating toward lower-cost alternatives in the used market. Familiar OEM leaders remain steady at the top of market share Despite shifts in vehicle registrations, leaders in new vehicle manufacturer market share have remained consistent. For instance, data through the fourth quarter of this year reveled General Motors (GM), Toyota, and Ford continue to hold the top three positions in new vehicle market share, with GM coming in at 17.4% share, followed by Toyota (16.5%), and Ford (12.6%). At the make level, Toyota held the top position for the fourth consecutive year in new vehicle market share, coming in at 14.1% through Q4 2025; they were followed by Ford (11.9%) and Chevrolet (11%). Sustained leadership in today’s market isn’t just about scale, it relies on how quickly manufacturers can respond and adapt to shifting consumer preferences and industry changes. Those that adapt their portfolios and go-to-market approaches will be best positioned not just to protect their share, but to grow it as the market continues to evolve. To learn more about vehicle market trends, view the full Automotive Market Trends Report: Q4 2025 presentation on demand.

A new reality for screening providers Everything about the candidate checked out. Their resume reflected the right experience. Their references confirmed it. The background screening process came back clean. From outside, there was no reason to hesitate. So, the company didn’t.  But within weeks, small inconsistencies began to surface. The employee struggled in ways that didn’t match their credentials. Follow-up questions led to vague answers. Eventually, a deeper review uncovered the issue; this wasn’t just a case of exaggeration. It was candidate fraud. And increasingly, it’s not just individuals acting alone.  In a widely reported scheme, foreign operatives posed as legitimate remote IT workers, using stolen identities and AI-assisted interviews to secure jobs at major Fortune 500 companies. Once hired, access was handed off, allowing bad actors to infiltrate corporate systems and generate millions in illicit revenue. In one case, a single individual funneled over $17 million to a foreign operation. These weren’t obvious scams. The candidates passed interviews. They cleared checks. And that’s exactly the point. For background screening and verification providers, this shift presents both a challenge and an opportunity. As candidate fraud becomes more sophisticated, your clients are no longer just looking to verify records – they’re looking to trust identity itself, and they’re looking to you to help them do it. The assumption that no longer holds For decades, hiring has relied on a simple premise: verify the records, resume, and you can trust the candidate. That model worked when identity was easier to validate in person. But in today’s digital-first hiring environment, identity can oftentimes be asserted, not proven. At the same time, identity-based fraud is accelerating. Synthetic identity fraud alone accounts for billions in annual losses, and employers are increasingly encountering candidates whose identities are far more difficult to validate than their resumes. This creates a critical disconnect: Organizations are still verifying records, but those records may be tied to identities that were never legitimate to begin with. Increasingly, they’re turning to their screening partners to close that gap. The reality of candidate fraud 31% of employers have interviewed candidates using a false identity Only 19% feel confident they can detect fraud in hiring 1 in 4 companies report losses of$50K+from fraudulent hires Why candidate fraud is getting harder to see The nature of candidate fraud has fundamentally changed. At one end of the spectrum, companies are still dealing with candidates who falsify resumes, costing businesses time and money when the truth comes to light later. But at the other end, the threat has escalated dramatically. Coordinated fraud rings are now using stolen identities and AI-assisted interviews to place individuals into remote roles, sometimes without ever revealing their identity. And this isn’t slowing down. According to Gartner, by 2028, 1 in 4 candidates could be fake, driven by AI, remote hiring, and identity manipulation. For screening providers, this introduces a new level of complexity. The challenge is no longer just delivering verified records; it’s helping clients surface risks that traditional screening processes were not designed to identify. What traditional screening still gets right None of this diminishes the importance of pre-employment screening. Verifying employment history, education, and background remains a critical part of responsible hiring, and it should. But even the most thorough screening process is designed to answer a specific question: Do the records align with the identity provided? What it does not answer is the question that matters most now: Is that identity real? That gap between record verification and identity validation is where modern fraud operates. And it represents an opportunity for screeners to expand their role from record validation to helping enable stronger identity confidence. The cost of believing everything is working When fraud moves through the hiring process undetected, the consequences aren’t always immediate, but they can be significant. There are financial risks, compliance exposure and potential access to sensitive systems. But there’s also a more subtle —and often overlooked — impact: The assumption that existing processes are working as intended. When fraudulent candidates pass through screening, it reinforces confidence in processes that may not be equipped for today’s threat landscape. Over time, that false sense of security can become a vulnerability. From screening provider to strategic partner As hiring evolves, so do expectations. Employers are no longer just looking for faster background checks - they’re looking for greater confidence in who they’re hiring. This shift creates an opportunity for screening providers to move upstream in the hiring process. By introducing identity verification earlier in the workflow, providers can help clients detect candidate fraud sooner, reduce downstream risk, and strengthen the integrity of hiring decisions.  More importantly, it allows providers to differentiate their offerings in an increasingly competitive market, shifting from a transactional service to a more strategic capability. A shift in thinking: Identity before everything else To address modern candidate fraud, organizations don’t just need better tools; they need a different starting point. Instead of beginning with records, leading providers are beginning with identity. They are asking a more fundamental question earlier in the process:  Is this person who they say they are? Is this person a real, consistent and verifiable person? When that foundation is established, everything that follows becomes more meaningful. Background checks become more reliable. Verification becomes more consistent. And the ability to detect candidate fraud improves, not because the process is longer, but because it’s more informed. In this model, identifying potential fraud becomes proactive rather than reactive. Why identity verification matters more now than ever The shift to remote and digital hiring hasn’t just changed how companies hire – it’s changed how fraud occurs. Today, a significant portion of fraudulent activity targets the employment process, making it a key point of exposure for identity misuse. In fact, 45% of all false document submissions now occur in the employment sector. In many cases, candidates who falsify information still progress through hiring workflows. A study revealed that 70% of candidates who falsify information still get hired. This reinforces today’s reality: Fraud is no longer slipping through the cracks; it’s moving through the front door. How Experian helps close the identity gap Experian® helps background screeners and verification providers bridge the gap between who a candidate claims to be and who they are. By combining identity verification, fraud detection, and verification solutions, Experian enables providers to enhance their existing solutions – without disrupting their workflows. This allows you to extend your value beyond traditional screening, help clients detect candidate fraud earlier, and strengthen confidence in hiring outcomes.   The result is not just better screening, it’s a stronger strategic position in your clients’ hiring ecosystem, one that reduces risk while improving speed and confidence. Candidate fraud isn’t an edge case anymore. It reflects a broader shift in how identity works in a digital world. And while traditional screening remains essential, it may not be sufficient on its own. Because if identity is uncertain, every subsequent check is built on unstable ground. But when identity is established earlier in the process, everything that follows becomes more dependable. Don’t just verify the candidate records, verify the identityLearn how Experian helps screening providers embed identity verification at the start of the hiring journey to help detect candidate fraud earlier, reduce risk, and strengthen screening outcomes.  Explore Experian’s Fraud Prevention Playbook for Pre-Employment Screening FAQs

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Model inventories are rapidly expanding. AI-enabled tools are entering workflows that were once deterministic and decisioning environments are more interconnected than ever. At the same time, regulatory scrutiny around model risk management continues to intensify. In many institutions, classification determines validation depth, monitoring intensity, and escalation pathways while informing board reporting. If classification is wrong, every downstream control is misaligned. And, in 2026, model classification is no longer just about assigning a tier, but rather about understanding data lineage, use case evolution, interdependencies, and governance accountability in a decentralized, AI-driven environment. We recently spoke with Mark Longman, Director of Analytics and Regulatory Technology, and here are some of his thoughts around five blind spots risk and compliance leaders should consider addressing now. 1. The “Set It and Forget It” Mentality The Blind Spot Model classification frameworks are often designed during a regulatory remediation effort or inventory modernization initiative. Once documented and approved, they can remain largely unchanged for years. However, model risk management is an ongoing process. “There’s really no sort of one and done when it comes to model risk management,” said Longman. Why It Matters Classification is not merely descriptive, it’s prescriptive. It drives the depth of validation, the frequency of monitoring, the intensity of governance oversight and the level of senior management visibility. As Longman notes, data fragmentation is compounding the challenge. “There’s data everywhere – internal, cloud, even shadow IT – and it’s tough to get a clear view into the inputs into the models,” he said. When inputs are unclear, tiering becomes inherently subjective and if classification frameworks are not reviewed regularly, governance intensity can become misaligned with real exposure. Therefore, static classification is a growing risk, especially in a world of rapidly expanding AI use cases. In a supervisory environment that continues to scrutinize model definitions, particularly as AI tools proliferate, a dynamic, periodically refreshed classification process can demonstrate institutional vigilance. 2. Assuming Third-Party Models Reduce Governance Accountability The Blind SpotThere is often an implicit belief that vendor-provided models carry less governance burden because they were developed externally. Why It Matters Vendor provided models continue to grow, particularly in AI-driven solutions, but supervisory expectations remain firm. “Third-party models do not diminish the responsibility of the institution for its governance and oversight of the model – whether it’s monitoring, ongoing validation, just evaluating model drift” Longman said. “The board and senior managers are responsible to make sure that these models are performing as expected and that includes third-party models.” Regulators consistently emphasize that institutions remain responsible for the outcomes produced by models used in their decisioning environments, regardless of origin. If a vendor model influences credit approvals, pricing, fraud decisions, or capital calculations, it directly affects customers, financial performance and compliance exposure. Treating third-party models as inherently lower risk can also distort internal tiering frameworks. When vendor models are under-classified, validation depth and monitoring rigor may be insufficient relative to their true impact. 3. Limited Situational Awareness of Model Interdependencies The Blind SpotModern decisioning environments are interconnected ecosystems. Forecasting models may influence reserve calculations. Marketing models may be repurposed across product lines. Data transformations may feed multiple downstream models simultaneously. Why It Matters Risk often flows across interdependencies. When upstream models degrade in performance or introduce bias, downstream models inherit that exposure. If multiple material decisions depend on the same data transformation or feature engineering process, concentration risk emerges. Without visibility into these dependencies, tiering assessments may underestimate cumulative risk, and monitoring frameworks may fail to detect systemic vulnerabilities. “There has to be a holistic view of what models are being used for – and really somebody to ensure there’s not that overlap across models,” Longman said. Supervisors are increasingly interested in understanding how model risk propagates through business processes. When institutions cannot articulate how models interact, it raises broader concerns about situational awareness and control effectiveness. Therefore, capturing interdependencies within the classification framework enhances more than documentation. It enables more accurate tiering, more targeted monitoring and more informed governance oversight. 4. Excluding Models Without Defensible Rationale The Blind SpotGray-area tools frequently sit outside formal inventories: rule-based engines, spreadsheet models, scenario calculators, heuristic decision aids, or emerging AI tools used for analysis and summarization. These tools may not neatly fit legacy definitions of a “model,” and so they are sometimes excluded without robust documentation. Why It Matters Regulatory definitions of “model” have broadened over time. What creates risk is the absence of defensible reasoning and documentation. Longman describes the risk clearly: “Some [teams] are deploying AI solutions that are sort of unbeknownst to the model risk management community – and almost creating what you might think of as a shadow model inventory.” Without visibility, institutions cannot confidently characterize use, trace inputs, or assign appropriate tiers, according to Longman. It also undermines the credibility of the official inventory during examinations. A well-governed program can articulate why certain tools fall outside model risk management scope, referencing documented criteria aligned with regulatory guidance. Without that evidence, exclusions can appear arbitrary, suggesting gaps in oversight. 5. Inconsistent or Subjective Classification Frameworks The Blind SpotAs inventories scale and governance teams expand, classification decisions are often distributed across reviewers. Over time, discrepancies can emerge. Why It Matters Inconsistency undermines both risk management and regulatory confidence. If two models with comparable use cases and impact profiles are assigned different tiers without clear justification, it signals that the framework is not being applied uniformly. AI adds even more complexity. When it comes to emerging AI model governance versus traditional model governance, there’s a lot to unpack, says Longman: “The AI models themselves are a lot more complicated than your traditional logistic or multiple regression models. The data, the prompting, you need to monitor the prompts that the LLMs for example are responding to and you need to make sure you can have what you may think of as prompt drift,” Longman said. As frameworks evolve, particularly to incorporate AI, automation, and new regulatory interpretations, institutions must ensure that changes are cascaded across the entire inventory. Partial updates or selective reclassification introduce fragmentation. Longman recommends formalizing classification through a structured decision tree embedded in policy to ensure consistent outcomes across business units. Beyond clear documentation, a strong classification program is applied consistently, measured objectively, and periodically reassessed across the full portfolio. BONUS – 6. Elevating Classification with Data-Level Visibility Some institutions are extending classification discipline beyond models to the data layer itself. Longman describes organizations that maintain not only a model inventory, but a data inventory, mapping variables to the models they influence. This approach allows institutions to quickly assess downstream effects when operational or environmental changes occur including system updates or even natural disasters affecting payment behavior. In an AI-driven environment, traceability may become a competitive differentiator. Conclusion Model classification is foundational. It determines how risk is measured, monitored, escalated, and reported. In a rapidly evolving regulatory and technological environment, it cannot remain static. Institutions that invest now in transparency, consistency, and data-level visibility will not only reduce supervisory friction – they will build a governance framework capable of supporting the next generation of AI-enabled decisioning. Learn more