Every exam cycle starts with the same scramble: pull the policy, find the version that was actually in force, reconcile it to the control, locate the evidence the control was operating, and stitch a narrative the examiner can follow from citation to artifact. Meanwhile MRAs and MRIAs from the last exam are still aging, regulatory change management lives in a shared drive, and third-party AI is governed (if at all) in a spreadsheet that nobody outside compliance has read.
OCC Heightened Standards, Fed SR 11-7 and SR 13-19, the FFIEC IT Examination Handbook, NAIC’s Model Audit Rule and AI Bulletin, ISO/IEC 42001, the NIST AI RMF, and Pattern 14 all demand the same thing in different vocabulary: evidence that the control was operating, on the day the decision was made, traceable to a citation. The existing toolset cannot produce that on demand.
If you cannot cite it, you cannot defend it. Stronghold cites it.