Five Steps to Governed AI

Chapter Nine

The Discipline Applied


Ten operations, laid out the same way so the pattern is visible before the detail. The vertical is incidental: swap the custodian for a carrier, the ledger for an ERP, and the five steps run unchanged.

Ten operations · Fifty passes through the same five steps

09.1  /  Skill catalog

A sample of sixty, by category.

Each Skill is a process that has already been through the five steps once. The ten marked with a gold dot are worked through in full below.

DATA & RECONCILIATION
Standing Instruction Recon
Platform against custodian, daily
Portfolio Drift Check
Holdings against policy bands
AUM Reconciliation
Feed against ledger at close
Cash Position Monitor
Low balance and sweep alerts
Data Quality Audit
Field completeness by system
BILLING & FEES
Fee Billing Validation
Agreement terms against invoice
Commission Reconciliation
Payout against production
Invoice Matcher
Line item to source record
Billing Exception Detector
Variance with root cause
Fee Tier Auditor
Breakpoints and household rollup
ONBOARDING & OFFBOARDING
Account Opening Filler
Signed docs to custodial form
Client Doc Collector
Requests, receipts, reminders
Onboarding Form Validation
Blocks until every rule passes
Offboarding Checklist
Closure steps and confirmations
Transfer Coordinator
In-kind position tracking
CONTROLS & COMPLIANCE
IPS Drift Compliance Check
Drift, bands, signature currency
KYC Collection and Verification
Collection and escalation
ADV Update Monitor
Change detection and filing dates
Wire and ACH Validation
Standing instructions and limits
Regulatory Calendar
Obligations by date and owner
DOCUMENT INTELLIGENCE
PDF Extractor
Structured fields from any form
Agreement Parser
Terms, rates, exceptions
Statement Reader
Positions and transactions
Tax Return Analyzer
Schedules and carryforwards
Policy Bound Setup
Record, renewal, welcome, filing
60+
SKILLS IN THE CATALOG
The catalog grows as firms contribute the processes they have already disciplined.
Use case 01Controls & compliance

IPS Drift Compliance Check

Know before your client does that a portfolio has drifted past the policy that governs it.

Who feels it · Chief Compliance Officer

40+Hours quarterly

A compliance analyst opens each IPS, transcribes target allocations into a spreadsheet, pulls holdings from the portfolio system, and calculates drift per asset class for every account under management.

Industry estimate

The workflow

INPUTIPS DOCUMENTS  +  PORTFOLIO HOLDINGS
THE PROCESS
EXTRACT TARGETS
PULL HOLDINGS
CALCULATE DRIFT
CHECK SIGNATURE
RULES CHECKDRIFT THRESHOLD: 3% WARNING, 5% ACTION
Output · What the human receives
A per-advisor report showing every account past threshold, the exact deviation, whether the IPS is current, and a recommended action.

What the agent does

  1. Reads each IPS document, pulling target allocations, tolerance bands and restrictions into a structured record.
  2. Queries the portfolio management system for current holdings and calculates actual allocation per asset class.
  3. Compares actual against target and flags any position past the stated drift threshold.
  4. Checks for low cash and confirms the IPS carries a valid signature and a review date inside twelve months.
  5. Produces a per-advisor exception report with the drift amount and the recommended rebalancing action.

Five steps mapped

DECIDEWhich IPS fields are rules: target, band, restriction.
GROUNDThe portfolio system API is the single source for holdings.
CALIBRATEFifty accounts with pre-calculated drift confirm the math.
PROVECompliance reviews flagged exceptions before any trade.
OPERATEWeekly, on a schedule, exception-only output.
40+ hours quarterlyA 15-minute review of flagged exceptions
Use case 02Billing & fees

Fee Billing Validation

Billing errors caught while they are still a variance, not after the client has read the invoice.

Who feels it · Controller / CFO

3–5Days per billing cycle

A billing analyst cross-references each client’s agreement fee schedule, custodian-reported AUM and the generated invoice, line by line, every quarter.

Industry estimate

Fee errors are estimated to cost advisory firms $50K to $150K a year in clawbacks and attrition.

The workflow

INPUTAGREEMENTS  +  CUSTODIAN AUM  +  INVOICE
THE PROCESS
EXTRACT TERMS
APPLY TO AUM
RECALCULATE
COMPARE
RULES CHECKFEE SCHEDULE RULES: TIER, BREAKPOINT, HOUSEHOLD
Output · What the human receives
A billing exception report listing every account where the invoice does not match the calculated fee, with the variance, the likely cause and a suggested correction.

What the agent does

  1. Extracts fee schedule terms from advisory agreements: tiered rates, breakpoints, caps, household aggregation.
  2. Pulls actual AUM from custodian statements or data feeds for the billing period.
  3. Calculates what the fee should be, applying the agreement terms to the actual AUM.
  4. Compares the calculated fee against the invoice the billing system produced.
  5. Flags every discrepancy with the dollar variance, the root cause and a route to the controller.

Five steps mapped

DECIDEEvery fee variant the firm uses: flat, tiered, breakpoint, household.
GROUNDAgreements hold the rates. Custodian feeds hold the AUM.
CALIBRATELast quarter’s billing, against corrections humans already caught.
PROVEThe controller approves each flag before any adjustment.
OPERATEEach billing cycle, split clean from exception.
3 to 5 days per cycleA same-morning variance report
Use case 03Finance operations

Vendor Invoice Validation

Every invoice checked against the purchase order and the policy before the payment leaves.

Who feels it · Controller / VP Finance

15–30Minutes per invoice

An AP analyst matches each invoice to its purchase order and receipt, re-checks totals, freight and tax, verifies the approval threshold, and chases sign-offs by email.

Industry estimate

A mid-size firm processes thousands of invoices a quarter, each carrying its own threshold, variance and approval rules.

The workflow

INPUTINVOICE  +  PURCHASE ORDER  +  RECEIPT
THE PROCESS
EXTRACT FIELDS
MATCH TO PO
APPLY THRESHOLDS
ROUTE VARIANCES
RULES CHECKTHRESHOLD AND VARIANCE RULES: R 2.1, R 3.4, R 5.0
Output · What the human receives
A payment queue where every invoice carries its checks: matched, within threshold, approved by the right person, with variance exceptions held for the controller.

What the agent does

  1. Extracts vendor, amounts, line items, tax and payment terms from the incoming invoice.
  2. Matches the invoice to its purchase order and goods receipt, line by line.
  3. Applies the firm’s thresholds: auto-approve under $5K on an exact match, manager sign-off to $10K, VP Finance above.
  4. Routes any variance above 2% from the PO to the controller, with the delta and the likely cause.
  5. Queues approved payments and logs every check, threshold and sign-off as it goes.

Five steps mapped

DECIDEThresholds, variance limits and who approves at each tier, signed by VP Finance.
GROUNDThe AP system is truth for amounts. The ERP holds the purchase orders.
CALIBRATEA quarter of historical invoices, including the ones corrected by hand.
PROVEEvery payment checked against R 2.1, R 3.4 and R 5.0 before it queues.
OPERATEPer invoice, on arrival, each check attached before anything queues.
15 to 30 minutes per invoiceExceptions only, everything else queued with proof
Use case 04Onboarding

Client Onboarding Form Validation and Routing

Engagements start on the day the advisor submits, not three round-trips later.

Who feels it · Operations Manager / Head of Finance

9 in 10Forms arrive incomplete

Finance receives a form with fields missing, emails the advisor for corrections, waits days for a reply, and repeats the cycle two or three times per new engagement.

Industry estimate

The workflow

INPUTADVISOR SUBMISSION
THE PROCESS
VALIDATE FIELDS
APPLY CONDITIONS
BLOCK IF INVALID
ROUTE TO APPROVER
RULES CHECKSUBMISSION BLOCKED UNTIL EVERY RULE PASSES
Output · What the human receives
A validated, approved engagement form delivered to finance in a structured format, with a trail showing who submitted, who approved and when.

What the agent does

  1. Presents a form with mandatory fields, conditional logic and validation as the advisor types.
  2. Blocks submission until every rule passes, so incomplete forms never leave the advisor’s desk.
  3. Routes the completed form to the division leader for a single approve or reject.
  4. On reject, returns it to the advisor with specific notes on what needs correcting.
  5. On approval, delivers the validated form to finance with every field structured for processing.

Five steps mapped

DECIDEEvery field: which are mandatory, which are conditional on another answer.
GROUNDFee schedules and the approval hierarchy come from firm policy.
CALIBRATETwenty forms with planted errors against every validation rule.
PROVEDivision leader approval sits inside the flow, not beside it.
OPERATELive on every engagement. No form reaches finance unvalidated.
9 in 10 forms incompleteNo form reaches finance unvalidated
Use case 05Finance & controls

Expense Policy Audit

The $9,400 dinner gets caught before it is reimbursed, not three months later.

Who feels it · Controller / CFO

5–10Minutes of review per report

A controller reads each report against the policy: per-head caps, spend-class limits, receipt rules, pre-approvals. Most reports are fine. The expensive one looks fine too.

Industry estimate

The workflow

INPUTEXPENSE REPORT  +  RECEIPTS
THE PROCESS
EXTRACT FIELDS
APPLY POLICY
DO THE MATH
HOLD OR PASS
RULES CHECKPER-HEAD CAPS AND PRE-APPROVAL RULES, AS WRITTEN
Output · What the human receives
A reimbursement queue where every report passed the written policy, and an exception list where each hold names the rule that stopped it.

What the agent does

  1. Extracts merchant, amount, attendees, spend class and receipt data from each submitted report.
  2. Applies the written policy: per-head caps, per-event limits, class rules, pre-approval requirements.
  3. Does the math a pattern match skips: $9,400 across two attendees is $4,700 a head against a $150 cap.
  4. Flags the violation with the rule named and the delta shown, and holds the reimbursement.
  5. Routes clean reports for payment and exceptions to the controller, logging every check.

Five steps mapped

DECIDEEvery cap and limit in the policy, including the per-head rule nobody had put in a spec.
GROUNDThe policy as written is truth. The report is the input, never the rule.
CALIBRATELast year’s reports, including the ones the controller caught by eye.
PROVEEvery reimbursement checked against the policy before payment. Pass or hold, rule named.
OPERATEOn every submission, with the trail written as the checks run.
A controller reading every report by eyeExceptions only, each with the rule named
Use case 06Operations & controls

Wire and ACH Validation

Every transfer checked against standing instructions and approval limits before the money moves.

Who feels it · Operations Manager / Wire Desk

15–20Minutes per request

A wire desk analyst pulls the client’s standing instructions, verifies the bank details match, checks the amount against approval thresholds, routes to signers, and documents each step for audit.

Industry estimate

The workflow

INPUTWIRE OR ACH REQUEST
THE PROCESS
EXTRACT FIELDS
MATCH INSTRUCTION
APPLY THRESHOLD
VERIFY BANK
RULES CHECKAPPROVAL AUTHORITY MATRIX: SINGLE OR DUAL SIGNER
Output · What the human receives
A validation summary per request showing pass or fail on each check, the routing decision with its reason, and a complete log from receipt to approval.

What the agent does

  1. Extracts the sending account, receiving bank, beneficiary account, amount and stated purpose.
  2. Checks whether a matching standing instruction exists and whether every detail agrees with it.
  3. Applies the threshold rules: single signer below the firm limit, dual signer above it.
  4. Verifies bank details against known-good records, including routing validation and format checks.
  5. Routes to the approvers with a summary of what passed and what needs judgment, logging every step.

Five steps mapped

DECIDEThreshold tiers, approval authority, fields that must match exactly.
GROUNDStanding instructions are truth. Firm policy sets the thresholds.
CALIBRATEForty historical requests, including ten that were rejected.
PROVENo wire executes without approval. The agent validates, never authorizes.
OPERATEReal time, per request, with the log written as it goes.
15 to 20 minutes per requestA validated summary waiting at the desk
Use case 07Insurance operations

Policy Bound: Setup and Calendar

Nothing about a bound policy depends on someone remembering to key it in.

Who feels it · Account Manager / Agency Operations

30+Minutes per binding

An account manager reads the declaration page, keys carrier, policy number, insured, limits, dates and premium into the book-of-business system, sets a reminder, drafts a welcome note and files the document.

Industry estimate

The workflow

INPUTDECLARATION PAGE
THE PROCESS
EXTRACT POLICY DATA
CREATE RECORD
SET RENEWAL
SEND WELCOME
RULES CHECKFILING AND NAMING CONVENTION
Output · What the human receives
A populated policy record, a renewal reminder on the calendar, a welcome note sent to the insured, and the declaration page filed where it belongs.

What the agent does

  1. Extracts insured name, carrier, policy number, coverage, limits, deductibles, dates and premium from the declaration page.
  2. Creates the policy record in the book-of-business system with every field populated.
  3. Sets a renewal reminder ninety days before expiry, assigned to the responsible account manager.
  4. Sends a welcome communication to the insured confirming coverage, with the key details summarized.
  5. Files the declaration page in the correct client folder under the firm’s naming convention.

Five steps mapped

DECIDEEvery declaration page field, plus filing and naming conventions.
GROUNDThe declaration page is truth. The management system is the target.
CALIBRATEThirty historical pages across five carrier formats.
PROVEThe account manager confirms or corrects what was entered.
OPERATEOn every binding notification, with no entry step left.
30 or more minutes per bindingA record, a reminder and a filed page
Use case 08Controls & compliance

KYC Collection and Verification

Compliance spends its time reading documents rather than chasing them.

Who feels it · Compliance Officer / AML Analyst

3–6Weeks per campaign

An analyst exports the clients due, sends individual requests, tracks replies in a spreadsheet, sends follow-ups by hand, and reviews each document for validity when it finally arrives.

Industry estimate

A refresh campaign is estimated to need five or more manual follow-ups per client.

The workflow

INPUTCOMPLIANCE REGISTER
THE PROCESS
BUILD LIST
REQUEST DOCS
VALIDATE
ESCALATE
RULES CHECKENTITY DOCUMENT RULES BY TYPE AND JURISDICTION
Output · What the human receives
A status view per client of complete, pending or overdue, validated documents filed in the compliance system, and an escalation log with the full history.

What the agent does

  1. Monitors expiry dates and builds a collection list sixty days before each refresh deadline.
  2. Sends requests naming exactly which documents are needed for that entity type.
  3. Validates what arrives: identity not expired, address proof inside ninety days, entity papers matching the registered name.
  4. Updates the compliance tracker with status, receipt date and validation result per client.
  5. Escalates non-responders on schedule: reminder at day seven, notice at fourteen, relationship manager at twenty-one.

Five steps mapped

DECIDEDocument requirements per entity type and jurisdiction.
GROUNDThe compliance register defines who is due and when.
CALIBRATEA mock campaign of fifty records with expired and mismatched papers.
PROVECompliance reviews any document that fails validation.
OPERATEContinuous. Collection at sixty days, escalation on schedule.
3 to 6 weeks per campaignA live status view, always current
Use case 09Insurance operations

Claims Intake and Coverage Verification

Coverage confirmed and reserves set before the claim reaches an adjuster, not after.

Who feels it · Claims Manager / TPA Operations

25–40Minutes per notice

A claims handler reads the first notice of loss, pulls the policy, confirms coverage was in force on the date of loss, checks limits, deductibles and exclusions, and keys the claim in before anyone can be assigned.

Industry estimate

The workflow

INPUTFIRST NOTICE OF LOSS  +  POLICY
THE PROCESS
EXTRACT LOSS
VERIFY IN FORCE
CHECK COVERAGE
SET RESERVES
RULES CHECKCOVERAGE, EXCLUSION AND RESERVING RULES, AS WRITTEN
Output · What the human receives
A claim record ready for assignment, with coverage confirmed, reserves set per the rules, and every coverage question flagged with the clause that raised it.

What the agent does

  1. Extracts date of loss, cause, parties and damage details from the notice, whatever channel it arrives on.
  2. Pulls the policy and confirms it was in force on the date of loss, including lapses and endorsements.
  3. Checks the loss against coverage, limits, deductibles and exclusions, as written in the policy.
  4. Creates the claim record with reserves set per the firm’s reserving rules, and flags coverage questions.
  5. Routes clean claims to assignment and exceptions to a senior adjuster, logging every check.

Five steps mapped

DECIDEWhat counts as covered, excluded and escalation-worthy, signed by claims leadership.
GROUNDThe policy admin system is truth for coverage. The notice is input, never authority.
CALIBRATESixty historical claims, including denials that were later overturned.
PROVENo coverage position reaches an insured without the clause named. Pass or hold.
OPERATEOn every notice, any channel, with the file built as it goes.
25 to 40 minutes per noticeAssignment-ready claims, exceptions flagged
Use case 10Banks & credit unions

Loan File Completeness and Policy Check

Underwriters underwrite. The file arrives complete, calculated and checked against policy.

Who feels it · Chief Lending Officer / Head of Underwriting

2–3Days of chase per file

A loan processor checks each file for required documents, recalculates ratios, verifies the file against lending policy, and emails the member or the officer for whatever is missing, file by file.

Industry estimate

The workflow

INPUTLOAN APPLICATION FILE
THE PROCESS
CHECK DOCS
EXTRACT DATA
RECALCULATE RATIOS
FLAG EXCEPTIONS
RULES CHECKLENDING POLICY: DTI, LTV AND EXCEPTION THRESHOLDS
Output · What the human receives
An underwriting-ready file: documents complete, ratios calculated and checked against policy, exceptions named, and one request list for anything missing.

What the agent does

  1. Checks the application file against the required-document list for that loan type.
  2. Extracts income, obligations, collateral value and score data from the file’s documents.
  3. Recalculates DTI and LTV and checks them against the lending policy’s thresholds.
  4. Flags policy exceptions with the rule named, and requests missing items in one pass, not five.
  5. Delivers underwriting-ready files with the checks and the trail attached.

Five steps mapped

DECIDERequired documents and thresholds per loan type, signed by the credit committee.
GROUNDThe core system and the file are read live. The policy as written sets the thresholds.
CALIBRATEFifty funded files and ten declines, against what underwriting actually did.
PROVENo file reaches underwriting with an unchecked ratio. Exceptions carry the rule.
OPERATEOn every application, with completeness enforced before review time is spent.
2 to 3 days of chase per fileUnderwriting-ready files, first pass

09.2  /  Integration map

A connection, not a data project.

Step two asks which systems hold the truth. These are the ones already connected, which means the answer is a configuration rather than a build.

CustodiansSchwab · Fidelity · Pershing · Wells Fargo
Portfolio systemsOrion · Black Diamond · Tamarac
CRMWealthbox · Salesforce · Redtail
ComplianceRegEd · ComplySci
DocumentDocuSign · ShareFile · Google Drive
CommunicationOutlook · Gmail
BillingOrion Billing · BillFin

PLUS SPREADSHEETS, SFTP DROPS AND ANY DOCUMENTED API

40+
SYSTEMS CONNECTED
PitCrew Factory, the platform in chapter ten, reads from the stack you already run. Nothing is migrated, and no system is asked to become the system of record unless you name it as one.

09.3  /  The ten, in one view

Different operations. The same five steps.

ProcessWho feels itToday
01IPS Drift Compliance CheckCHIEF COMPLIANCE OFFICER40+ hrs
02Fee Billing ValidationCONTROLLER3–5 days
03Vendor Invoice ValidationCONTROLLER / VP FINANCE15–30 min
04Client Onboarding Form Validation and RoutingOPERATIONS MANAGER9 in 10
05Expense Policy AuditCONTROLLER / CFO5–10 min
06Wire and ACH ValidationOPERATIONS MANAGER15–20 min
07Policy Bound: Setup and CalendarACCOUNT MANAGER30+ min
08KYC Collection and VerificationCOMPLIANCE OFFICER3–6 wks
09Claims Intake and Coverage VerificationCLAIMS MANAGER25–40 min
10Loan File Completeness and Policy CheckCHIEF LENDING OFFICER2–3 days
What the ten have in common

Every one of them was already a written-down process somewhere in the firm. None needed a smarter model. Each needed the firm’s judgment written down and the output made checkable.

The human stays

Every one keeps a human on the approval. The agent does the reading, the matching and the logging. The firm keeps the decision and the signature.

Chapter eleven gives five tests for choosing among them. Start where the cost is already visible.