Short pieces by C. Erik Larson on risk governance, model validation and the supervisory questions raised by new financial technology.
SR 26-2 places generative and agentic AI outside its scope. The four questions behind model validation still apply. What changes is how difficult they are to answer, and how much of what is presented as new is not.
A four-part series, September 25 – October 7, 2026
Toolkits, venues and chartered issuers are often described as one thing. Distinguishing them clarifies three risk management problems that remain unsolved.
A network that settles tokens on a gross basis around the clock and nets fiat once a business day is running deferred net settlement. Payment systems answered that problem long ago, and the answers belong in the rulebook.
Transaction monitoring systems are models, tuned against years of alert history. A new network has none, and permissioned access is not the same thing as monitoring.
Fragmentation across tokenized deposit networks is not mainly an inconvenience. The settlement and credit question underneath it has no answer yet, and the controls that would answer it are decades old.