CECL model validation

Adversarial by design: the trust layer behind our CECL validation

In pilot testing

FinLucidity is testing an evidence-based workflow for reviewing methods, data, assumptions, calculations, and governance, with documented findings and human review before broader availability.

Engagements are scoped by institution size and model complexity.

One rule, enforced in code

The system challenges and recalculates — it never fabricates a finding, a number, or a citation.

This is not a guideline the AI is merely asked to follow. Seven independent software gates stand between the analysis and anything a client reads.

Mechanical controls

The seven gates

GateWhat it enforces
1Number provenanceEvery tested figure must originate from a deterministic recalculation ledger. Numbers flow into the report from verified computations.
2Evidence-backed findingsA finding without a documented evidence reference is structurally suppressed, and every suppression is logged.
3Citation verificationEvery regulatory citation is checked against a verified library. An invented citation fails the report.
4Recalculation transparencyRecalculations show the bank’s figure and ours, together with the formula and inputs. Neither figure is silently adopted.
5Calibrated conclusionsConclusions use a fixed taxonomy. Mechanically blocked language prevents overstatement such as “certified” or a standalone “Validated.”
6Independence structureRequired limitations statements and a preserved management-response record keep accepted, modified, and rejected findings visible.
7Evidence is data, not instructionsClient documents are quarantined as data. Text inside an uploaded file cannot alter a procedure, guardrail, or conclusion.

Effective challenge · August 2026

Then we challenged it

The gate layer went through iterative challenge review. Fresh, unscripted probes attempted to pass fabricated citations, unsupported findings, overstated conclusions, and hidden instructions through each control. Every correction was challenged again with a new set of probes.

3

challenge rounds with freshly written probes

39

novel probes beyond 90 scripted checks

3

evasion paths found in review and closed

0

findings in the final round

Our shipping standard: a fix list going green is not a pass. The gate layer clears only when a fresh round of challenge probes, written against the fixed build, comes back clean.

Evidence boundary

The same discipline applies to your data

The workflow runs aggregate-first — no borrower personal information. Evidence arrives through an encrypted, time-boxed upload channel and is screened before any analysis step opens it. Client evidence remains separate from the public-data platform and raw evidence is deleted at engagement close.

Engagement output

What a bank receives

  • Validation report with a calibrated conclusion level
  • Findings register with supporting evidence
  • Management-response record
  • Evidence inventory
  • Workpaper index

Talk to us about a validation

We’ll discuss the institution, model complexity, evidence boundaries, and the scope appropriate for the engagement.

Request a CECL validation conversation

Prefer to talk? Call (706) 600-6431 or email hart@finlucidity.com.