AI Governance Manager

Senior leadership role to develop risk management tools, practices, and policies to identify, assess and report on Artificial Intelligence (AI) risk. This role ensures the organization’s AI risk management policies and strategies are in compliance with applicable regulations, industry best practices and standards, and strategic imperatives of the organization. Ensure consistent identification, evaluation, and escalation of all AI risks across the organization; decision making in line with the risk appetite; and appropriate consideration of all related corporate risks such as fair lending, cyber scurity, data privacy and societal impacts. Oversee the AI risk assessment processes, including related RCSA, AI risk appetite, key risk indicators, key performance indicators and related emerging risks. Develop capabilities for consistent risk reporting and aggregation across the risk pillars. Additionally, responsible for effective challenge of all first line of defense elements. Enhanced Management and Board reporting for all AI risks.

The AI governance manager provides on-going thought leadership in ongoing development of AI use cases. The position will:

  • Ensure awareness and manage the oversight of the AI risk management processes and related policies to foster compliance and monitoring of risk to the Corporation.
  • Provide review, challenge, and subject matter expert (SME) to support for AI use cases including the development, implementation, and monitoring of such processes, in accordance with Comerica policies and standards, and all associated laws and regulations and with the engagement of appropriate stakeholders (i.e., business owners, operations, application and systems, and risk management representatives), as necessary.
  • Provide reporting on the portfolio of AI use cases, related risks, and other issues, and making recommendations to the AIRWG, MROC, and other committees, as appropriate.
  • Escalate risk issues to the MROC and to other aligned risk governance committees, as appropriate.

Position Responsibilities:


  • Responsible for participating in industry forums to keep abreast of ever-changing laws and regulations as it relates to AI.
  • Create and implement the roadmap for AI Risk Management and adjust as necessary to ensure all AI within the organization adheres to CMA’s risk management culture.
  • Provide on-going thought leadership on AI framework and governance.

Operational Excellence:

  • Oversees and monitors all AI risk management activities for the Bank.
  • Leads a group of risk professionals who are responsible for educating risk owners, communicating risk policies and programs, identifying risks, developing assessments, providing input over controls and testing, advising on, and monitoring remediation activities and creating reporting.
  • Proactively advises first line business units on applicable AI risk standards, including keeping up to date with developments in the applicable laws, rules, standards and industry practices.
  • Proactively works with business unit management to identify and assess the use of AI models and related risks associated with business activities, ensuring alignment with the AI framework and policy.
  • Monitors and facilitates changes in business processes necessary to meet regulatory changes and mitigate AI risk exposure to the Bank.
  • Assist the first line of defense in identify AI related emerging risks; develop key risk indicators, analytics, and insights.


  • Report on AI Risk and related metrics to MROC, ERRC and ERC.
  • Member of Technology and Data Risk Committees.
  • Present AI risk assessment to Senior Management.
  • Manage AI related Audit and Regulatory exams.


  • Lead, coach and manage team members.
  • Develop and train a high-performing team.
  • Manage personnel processes for employees, including selection, training, performance management, compensation, disciplinary actions, development and retention.

Position Qualifications:

  • Master’s Degree from an accredited university in Data Science, Computer Science, IT, Mathematics, Statistics
  • 10 years of experience in AI related work in development or use
  • 10 years of experience working in financial industry, Fintech or similar fields
  • 10 years of experience in project management
  • 10 years of experience in managing or coordinating with diversified teams and across functions
  • 5 years of experience in risk management or risk governance

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