Advances in artificial intelligence (AI) and machine learning (ML) have led to increased adoption in the financial services sector. A prominent use for this technology is to assist in key compliance and risk functions, including the detection of fraud, money laundering, and other financial crimes and illicit finance, as well as trade manipulation — collectively referred to as “Risk AI/ML.” As the use of these models grows, so do questions about managing risks associated with the models. 

In particular, regulators, financial institutions, and technology service providers have been looking into whether existing Model Risk Management (MRM) guidance — which has traditionally been the regulatory regime applicable to managing model risk in the financial services industry — continues to be relevant for AI/ML models. And, if so, how should the guidance be interpreted and applied to this new technology?

As the financial sector increasingly adopts artificial intelligence and machine learning techniques, it is critical for regulators, financial companies and technology providers to work together to assure that there are clear rules of the road,” says Jo Ann Barefoot, AIR CEO and co-founder. “Updated guidelines on the responsible use of these models can help prevent novel technologies from causing harm, and can also open up better ways to combat risk in areas like money laundering, illicit finance, and fraud.

Our new white paper, written in partnership with the Alliance for Innovative Regulation (AIR), seeks to address that question, with the aim of fostering thought and dialogue among agencies, the financial services industry, risk model vendors, and entities interested in the performance, outputs, and compliance of models used to identify, mitigate, and combat risks in financial services. This white paper does not address issues that may arise with other applications of AI/ML in the financial services industry, such as consumer credit underwriting or models using generative AI or Large Language Models, which are better addressed iteratively. 

The paper argues that MRM guidance, given its broad, principles-based approach, continues to provide an appropriate framework for assessing financial institutions’ management of model risk, even for Risk AI/ML models. Working within an existing framework takes advantage of the knowledge and operational capabilities of institutions that already understand this framework, instead of having to create an entirely new approach, which generally takes longer to implement and make effective. Nonetheless, the paper recognizes that AI/ML models have unique traits and characteristics compared to conventional models, including their potential dynamism and pattern recognition capabilities. These distinctions must be in focus when considering how MRM guidance should be applied to Risk AI/ML models. 

Taking into account those unique aspects of AI/ML models, the paper offers specific observations and recommendations regarding the application of MRM guidance to Risk AI/ML models, including:

• Risk assessment: In assessing risk, it is important to recognize that AI/ML models are not inherently more risky than conventional models. A risk-tiering assessment must consider the targeted business application or process for which a model is used, as well as the model’s complexity and materiality. To assist in these assessments, regulators could clarify that the use of AI/ML alone does not place a model into a high-risk tier and publish further guidance to help set expectations regarding the materiality/risk ratings of AI/ML models as applied to common use cases.
• Safety and soundness: Due to the dynamic nature of Risk AI/ML models, reliance on extensive and ongoing testing focused on outcomes throughout the development and implementation stages of such models should be primary in satisfying regulatory expectations of soundness. To that end, the development of technical metrics and related testing benchmarks should be encouraged. Model “explainability,” while useful for purposes of understanding the specific outputs of AI/ML models, may be less effective or insufficient for establishing whether the model as a whole is sound and fit for purpose.
• Model documentation: The touchstone for the sufficiency of documentation should be what is needed for the bank to use and validate the model, and understand its design, theory, and logic. Disclosure of proprietary details, such as model code, is unnecessary and unhelpful in verifying the sufficiency of a model and would deter model builders from sharing best-in-class technology with financial institutions.
• Industry standards and best practices: Regulators should support the development of global standards and their use across the financial services and regulatory landscape by explicitly recognizing such standards as presumptive evidence of compliance with the MRM guidance and sound AI/ML risk mitigation practices. In addition, regulators should foster industry collaboration and training based on such standards.

Governance controls: Regulators should use guidance to advance the use of governance controls, including incremental rollouts and circuit breakers, as essential tools in mitigating risks associated with Risk AI/ML models.

In an era where AI technology has the potential to revolutionize financial services, we acknowledge the foresight of our regulators in setting a solid foundation and blueprint for navigating the labyrinth of potential risks through the MRM guidance,” says Philip Moyer, Global VP, AI and Business Solutions at Google Cloud. “We believe there is room for greater coherence and precision, enhanced risk-mitigation approaches, and refined best practices surrounding AI and ML risk models. Whether it’s in capacity building or information sharing, our call to action is for greater collaboration between regulators and financial institutions. We’re confident that our collective efforts today will help shape a more robust and resilient future for financial services.

We invite a discussion of additional considerations, including the importance of examiner and industry training and collaboration, as well as openness by regulators to continue to refine the MRM guidance as AI/ML technologies develop and standards emerge. 

Implementing our recommendations would advance several goals. It would help regulators, financial institutions, and technology providers work together to better serve their shared purpose of protecting the safety and soundness of the financial system. At the same time, implementing the recommendations and continuing work in this space would promote the adoption of cutting-edge technologies in the industry, including those that combat such scourges as money laundering, illicit finance, and fraud.

You can read the full white paper here.

Digital technology offers increasing flexibility and choice to consumers. As a result, the retail industry is dramatically shifting toward more tailored and personalized experiences for shoppers, and businesses are rethinking how they deliver value to customers.

This couldn’t be more true for the beauty retailing industry where leading companies are turning to digital technology to create customized shopping experiences.

At Google Cloud, we’re particularly excited about our work with Ulta Beauty, the largest beauty retailer in the United States with more than 1196 stores in all 50 states, and how the company is using Google Cloud technology solutions to power personalization and redefine beauty retailing.

Established in 1990, Ulta Beauty has had incredible success as a company, and as customers become more discerning and curious about their purchases, the company is finding new ways to meet their changing needs.

Recently, leaders at Ulta Beauty recognized a huge opportunity to complement and enhance the shopping experience by helping beauty enthusiasts navigate through more than 500 brands and 25,000 products carried in their stores and online channel.

They decided to leverage the data from Ulta Beauty’s successful Ultamate Rewards loyalty program to create and offer more unique and personalized user experiences.

With more than 30 million members generating data through sales, transactions, product reviews, and social media engagement, Ulta Beauty’s Loyalty Program creates a comprehensive data set, and the company sought the right technology partner to help organize, analyze and transform that data into valuable insights for its customers.

Ulta Beauty’s leaders knew they had an opportunity to leverage data analytics and machine learning to reach customers in new ways, enhance the guest experience, and continue to grow their active loyalty member base. After considering a number of cloud providers, they chose to expand their existing partnership with Google Cloud.

“Google Cloud listened to our needs and worked in tandem with our engineering team to address our challenges,” said Michelle Pacynski, vice president of digital innovation at Ulta Beauty. “The ease of working with the Google Cloud team and their breadth of experience made the decision a no-brainer, laying the foundation for a great partnership.”  

In 2019, Ulta Beauty announced it was working with Google Cloud Platform to unify and organize its data, using:

• BigQuery to perform data analysis and generate dynamic content, personalized product recommendations, and event-based messages for customers.
• Cloud Storage to provide highly available, secure, resilient and cost-effective access to data across the entire enterprise.
• Compute Engine for the high-performance scalability needed to grow with customer demand while painlessly migrating existing applications to the cloud.
• Anthos to build a hybrid cloud foundation that allows their applications to take advantage of all this data, combining the power and flexibility of GKE with the ability to leverage their existing investment in secure infrastructure on-premises.

Our partnership with Ulta Beauty has enabled increased engagement with customers in store and online, and the creation of new tools and capabilities, including a new Virtual Beauty Advisor tool to deliver tailored recommendations and help shoppers choose the right products, and a Customer Conversation Platform that’s enabling deeper connections with guests, ultimately driving customer loyalty.

“It’s been a really efficient process so far due in part to the ease of working with the Google team,” said Michelle Pacynski, vice president of digital innovation at Ulta Beauty. “They’re experienced, approachable, and their can-do style makes for a great partnership. They listened to our needs and worked in tandem with our engineering team, figuring things out, and getting it done.”

Headless Ecommerce

In the last couple of years there has been a shift in the way retailers approach ecommerce: where in the past development efforts were prioritized around building a solid foundation for backend transactions and operations now it is clear that companies in this space are focusing on differentiating themselves by creating unique shopping experiences that increase engagement and reduce friction. 

But how can development teams spend the necessary time designing and writing code for this kind of interactions while also having to seamlessly maintain ecommerce vital components like online catalogs, shopping carts and checkout payment processes? Enter headless commerce.  

Headless commerce (HC) helps companies of all sizes to innovate, develop and launch in less time and using fewer resources by decoupling backend and frontend. Headless solution providers empower online retailers by offering a balance between flexibility and optimization through pre-built api-accessible modules and components that can be easily plugged into their frontend architecture. This translates into rapid development while keeping desired levels of security, compliance, integration and responsiveness. 

This composable approach enables dev teams not only to create new features but also connect other ecommerce components with less effort which is critical when responding to business trends. But above all, the main benefit retailers receive from HC, is owning and controlling the frontend for an engaging customer journey as well as quickly launching new experiences.  

Google Cloud + commercetools

commercetools, a leader in the headless commerce space, has partnered with Google Cloud to make their cloud-native SaaS platform available in the Google Cloud Marketplace. With a flexible API system (REST API and GraphQL), commercetools’ architecture has been designed to meet the needs of demanding omnichannel ecommerce projects while offering real flexibility to modify or extend its features. It supports a variety of storefront providers like Vue Storefront, offers a large set of integrations and supports microservice-based architectures. All this while providing access to multiple programming languages (PHP, JS, Java) via its SDK tools. 

commercetools and Google Cloud provide development teams with all the tools to build high-quality digital commerce systems. Google Cloud’s scalability, AI/ML components, API management capabilities and CI/CD tools are a perfect fit to build frontend shopping experiences that easily integrate with the commercetools stack. Developers can take advantage of this compatibility by:

• Integrating systems with Google’s Retail Search, Recommendations AI and Vision Product Search
• Injecting serverless functions into commercetools using Google Cloud Functions
• Extending and integrating commercetools via Events handled by Pub/Sub
• Managing 3rd party, legacy, microservices and commercetools APIs with Apigee
• Selecting the Google Cloud region commercetools uses for zero latency for custom apps
• Expanding their microservice ecosystem with components like Cloud Storage, Cloud SQL, Firestore and BigQuery

Additionally, commercetools allows ecommerce solutions to tap into the wider Google Ecosystem by providing authoritative data via Merchant Center, advertising via product listing ads and selling via Google Shopping. 

Architecture Overview

As mentioned previously, headless commerce is increasingly preferred by retailers who want to own and control the ‘front-end’ for providing and enabling an engaging and differentiated user and shopping experiences. 

The approach involves a loosely coupled architecture that separates ‘front end’ from the ‘back end’ of a digital commerce application. The front end is typically built and managed by the retailer. They want to leverage an independent software vendor (ISV) offered, ready-to-use ‘back-end’ commerce building blocks for capabilities, such as product catalog, pricing, promotions, cart, shipping, account and others.

Most retailers want to invest their time and resources in building a front end that requires an agile development model to introduce new and tweaking existing user experiences to acquire and retain customers. A few retailers that do not have an in-house web development team may choose an ISV that offers ready to use front end. The front end is a web app and designed as a progressive web application (PWA) on Google Cloud. The backend is a headless commerce offered by an ISV, such as commercetools. The backend commerce capabilities are built as a set of microservices, exposed as APIs, run cloud-native and implemented as headless. It is commonly referred to as the  “MACH” solution. The API-first approach of the architecture allows easily integrating ‘best of breed’ capabilities built internally and/or offered by 3rd party ISVs.

Leveraging Google Cloud Components

The architecture of the front end will be implemented on Google Cloud and will integrate with the ISV’s headless commerce back end that runs natively in Google Cloud. 

The front end will be designed using cloud-native services for 

• PWA web app development (Google Kubernetes Engine, CI/CD services), 
• Google Product Discovery solution that includes Retail Search and Vision API Product Search for serving product search (text and image) and Recommendations AI for serving recommendations.
• Storage (Cloud Storage), Database (Cloud SQL, Cloud Firestore), and edge caching for content delivery (Cloud CDN) 
• Networking (Cloud DNS,  Global Load Balancing), and 
• Security (Cloud Armor for DDoS, API Defense for API protection) 

Additionally, API management (Apigee on Google Cloud) can be used to orchestrate interactions of the front end with the APIs of the backend commerce services. The API management’s capability will be used for accessing the services of on-premises systems, such as ERP, order management system (OMS), warehouse management system (WMS) as needed to support the functioning of digital commerce application.  Alternatively, depending on the frontend capabilities, developers can use middleware to build custom services and route requests. 

What’s next?

A considerable number of retailers have adopted headless commerce and are now focusing on adopting best practices and leveraging the agility that comes with this approach. Just like commercetools offers robust components that meet the retailer’s backend operational needs (Product Catalog, Order Management, Carts, Payments, etc), Google Cloud’s Compute, Networking, Severless and AI/ML services  provide the agility and flexibility required by development teams to quickly and easily extend their frontend capabilities. 

commercetools and Google Cloud work seamlessly together because they both prioritize ease of integration, scalability, security and iterability while providing ready-to-use building blocks. It also helps that commercetools backend runs on Google Cloud. Once an initial foundation of Google Cloud and commercetools has been established, adding new commerce modules and extending functionally of the current ones becomes a straightforward process that allows to route efforts to innovation initiatives. In the end, the main beneficiaries of this technical synergy are the shoppers that enjoy experiences which increase engagement and minimize friction. 

Alternatively, retailers can also save time and resources by relying on frontend integrations. commercetools offers a variety of third-party solutions that can effortlessly be added to a headless commerce architecture. These integrations as well as other important headless commerce extensions will be explored in future blog entries.  In the meantime, all the necessary tools to leverage headless commerce can be found in just one place: 

Get started with commercetools on the Google Cloud Marketplace today!

The home lending journey entails processing an immense number of documents daily from hundreds of thousands of borrowers. Currently, home lending document processing relies on some outdated digital models and a high dependency on manual labor, resulting in slow processing times and higher origination costs. Scaling a business that sorts through millions of documents daily, while increasing efficacy and accuracy, is no small feat. When it comes to applying for a mortgage loan, consumers expect a digital experience that’s as good as the in-person one. Roostify simplifies the home lending journey for lenders and their customers.

No time to spare: Overcoming document processing challenges with AI

Roostify provides enterprise cloud applications for mortgage and home lenders. In order to empower its customers to deliver a better, more personalized lending experience, they needed to automate and scale their in-house document parsing functionality.

As a key component of its document intelligence service, Roostify is leveraging Google Cloud’s Lending DocAI machine learning platform to automate processing documents required during a home loan application process, such as tax returns or bank statements with multi-language support. This partnership delivers data capture at scale, enabling Roostify customers to automatically identify document types from the uploaded file and to extract relevant entities such as wages, tax liabilities, names, and ID numbers for further processing, and make things move faster in the cumbersome lending process. 

Roostify’s solutions leverage Google Cloud’s Lending DocAI, which is built on the recently announced Document AI platform, a unified console for document processing. Customers can easily create and customize all the specialized parsers (e.g., mortgage lending documents and tax returns parsers) on the platform without the need to perform additional data mapping or training. All Google Cloud’s specialized parsers are fine-tuned to achieve industry-leading accuracy, helping customers and partners confidently unlock insights from documents with machine learning. Learn more about the solution from the GA launch blog and the overview video.

Integrating Lending DocAI’s intelligent document processing capabilities into the Roostify platform means more innovation for their customers and tangible results: faster loan processing times, fewer document intake errors, and lower origination costs. Additional support in Google Lending DAI for other languages and more documents like global Know Your Customer (KYC) documents or payroll reports is in the near future.

Full integration of AI solutions

Working together with Roostify’s platform team, we were able to help them solve their document processing challenge through integration of various GCP products such as Lending DocAI (LDAI), Data Loss Prevention (DLP) for redacting sensitive data, BigQuery for data warehousing and analytics, and Firestore for API status. To make it very safe and secure, all data was encrypted end-to-end at Rest and in Transit. LDAI won’t require any training data to process. It is an easy plug and play API.

Here is a sneak peek in the high level deployment architecture for LDAI in Roostify environment:

Here are the steps for processing data:

1. Receives document processing request from the client.
2. API Function directs requests to the pre-processing service. For Async requests a processing ID is generated and returned to the caller.
3. Pre-processing service sends the request for further processing (Long/short PDF conversion), calling other microservices and receives back the responses. Any error in the response received is then sent to the response processing service. 
4. If the response is synchronous, the pre-processing service directs it to the LDAI Invoker service. 
   1. If the response is asynchronous, the pre-processing service feeds it into the Cloud Pub/Sub service.
5. Cloud Pub/Sub service feeds the response back to the LDAI Invoker service.
6. LDAI Invoker service routes the request to the Google LDAI API for classification if there are multiple pages in the document.
7. Document will be split based on LDAI response and then saved in a GCS bucket for temporary storage.
8. LDAI entity interface for single page processing and then LDAI Invoker sends LDAI results to LDAI Response Processing
9. If a request is a synchronous request the LDAI Response Processor sends results to the API Function so that it can complete the synchronous call and respond to the rConnect caller.
   1. If the request is an asynchronous request the LDAI Response Processor will respond to the caller’s webhook and complete the transaction.
10. Finally, Data stored in the GCP bucket will be deleted.

All the responses that come from the LDAI API can optionally feed into BigQuery via the Response Processor, after parsing it through Data Loss Prevention (DLP) API to redact the PII/sensitive information.  Throughout the processing of both asynchronous and synchronous requests all transactions are logged using Cloud Logging.  For asynchronous transactions, the state is maintained throughout the process using Cloud Firestore.

Roostify currently uses this technology to power two different solutions: Roostify Document Intelligence and Roostify Beyond™. Roostify Document Intelligence is a real-time document capture, classification, and data extraction solution built for home lenders. It ingests documents uploaded by borrowers and loan officers, identifies the relevant documents, and extracts and classifies key information. Roostify Document Intelligence is available as a standalone API service to any home lender with any digital lending infrastructure already in place. 

Roostify Beyond™ is a robust suite of AI-powered solutions that enables home lenders to create intelligent experiences from start to close. It combines powerful data, insightful analytics, and meaningful visualization to streamline the underwriting process. Roostify Beyond™ is currently available only to Roostify customers as part of an Early Adopter program and will be rolled out to the market later this year.

Through this partnership, Roostify has enabled its customers to adopt a data-first approach to their home lending processes, which will lead to improved user experiences and significantly reduced loan processing times.

Fast track end-to-end deployment with Google Cloud AI Services (AIS)

Google AIS (Professional Services Organization), in collaboration with our partner Quantiphi, helped Roostify deploy this system into production and fast-tracked the development multifold to generate the final business value.

The partnership between Google Cloud and Roostify is just one of the latest examples of how we’re providing AI-powered solutions to solve business problems.