Bank examiners ask where the model came from, and model-origin audits form

Neither half of this opportunity is open, but neither is fully taken for banks. Generic model fingerprinting is fast becoming free: Cisco open-sourced a provenance kit in 2026, AIROM adds base-model links to AI-BOMs, and Palo Alto/Protect AI, HiddenLayer, Manifest and OpsMX all sell AI-BOM. All of these tools need direct access to weights or source code. None of them is aimed at bank model risk teams. A new entrant could still win by working out lineage for closed vendor software where the bank never sees the weights. That means fingerprinting behaviour through API traffic and outbound calls to model providers inside products from FIS, Jack Henry and fintech vendors. The entrant would then turn the findings into SR 11-7 and interagency third-party guidance inventory entries and examiner-ready evidence, and plug into existing bank governance tools like ValidMind or Credo AI rather than competing with them. On the attestation side, the SIG AI domain, the FS-ISAC workbook, Credo AI's Vendor Portal and ValidMind Advantage already cover AI vendor questionnaires. KY3P-style exchanges already handle the "fill it in once, share with every bank" model. A new questionnaire would therefore struggle unless it gets a consortium or the big core-banking vendors on board. A narrower opening is a specific, evidence-backed attestation of model origin and derivation, such as which base model, which fine-tunes and what jurisdiction, verified by fingerprinting rather than self-declared. Existing questionnaires do not appear to capture that in a structured way. The idea is most defensible if the scanner and the attestation are sold together.

• Cisco Model Provenance Kit (open source)

  Free open-source toolkit and CLI released in 2026. It checks whether a model comes from a known base model using metadata, tokenizer similarity and weight-level signals. Scan mode matches against a fingerprint database hosted on Hugging Face, reported at around 150 base models. This covers the core of the fingerprinting idea at no cost, but only for open-weight models you can access directly.

• AIROM (open-source AIBOM scanner)

  Early-stage Go scanner. It inventories models, datasets, prompts and vector stores, reads weight headers, and links PEFT/LoRA and Hugging Face derivatives back to their base models. Output is CycloneDX 1.6 and SARIF.

• Palo Alto Networks Prisma AIRS (Protect AI)

  Palo Alto acquired Protect AI's model scanning and AI-BOM work in 2025. Its AI-BOM covers models, datasets and how they relate, but the focus is security, not model risk management.

• HiddenLayer

  An AI security platform that does model scanning and AI-BOM. Lineage is a secondary feature next to detecting malicious payloads.

• Manifest

  An SBOM vendor that is extending into AI-BOM for AI assets in software supply chains. That position makes it the most natural rival for vendor-software model disclosure.

• OpsMX Delivery Shield AI-BOM scan

  Inventories models, datasets and agents from source code, containers and pipelines.

• Credo AI Vendor Portal

  Gathers AI-specific risk evidence from vendors and tracks third-party AI systems centrally. It is the closest existing product to the attestation idea, though each buyer runs its own collection rather than vendors sharing one record with all clients.

• ValidMind Advantage program

  Helps fintech vendors test and document their models against SR 11-7 so banks can accept them. It is aimed at bank model risk teams and runs on the vendor side, which puts it close to the attestation exchange idea.

• Shared Assessments SIG (AI domain)

  The standard shared vendor questionnaire, licensed through TPRM platforms. A secondary source says SIG 2026 has an Artificial Intelligence domain mapped to NIST AI RMF and ISO 42001. That makes it the default place for a standard AI vendor questionnaire.

• FS-ISAC Generative AI Vendor Risk Assessment

  A free 2024 workbook and guide for financial institutions assessing generative AI vendors, referenced to FFIEC and the interagency third-party guidance. Model origin is not a central focus.

• KY3P (S&P Global)

  An existing exchange for financial services where a vendor fills in one assessment and shares it with many banks. It could add an AI model-origin module.

Checked 2026-10-13