- Before
- Searches the instruction PDFs, or copies last quarter, for the lease and loan detail Equipment Finance feeds to Schedule RC-C.
- Now
- Asks in plain words and gets the line, the near miss and the amounts the bank filed before, then saves the answer to the working papers.
One question on the form, from asked to approved
Corvane National Bank, a $92 billion regional bank, is on day 22 of the Q3 2026 filing window; the FFIEC 031 is due Friday, Oct 30. Here is one morning, screen by screen, in the working solution.
- 01Thursday, 09:42
“Where do we report the $240M of leases to municipalities?”
Marcus Oyelaran · Line-of-Business Finance PreparerEquipment Finance holds 312 leases to 87 lessees: counties, school districts, transit and water authorities, $240.6 million of net investment at Sep 30 in general ledger accounts 14520 and 14525. Marcus types the question in plain words, on the FFIEC 031 for Q3 2026. The agents' plan streams as they work: the Answer agent searches 1,410 pages and finds 9 passages, then the Change, Precedent and Mapping agents and the citation check each report what they found.
“The agents are working. Nothing is shown until every layer is cited.”
- 0234 seconds later
Item 10.b, All other leases. Not item 8.
Answer agentOne verdict line: report it in Schedule RC-C, Part I, item 10.b, All other leases, in column A, and in the item 10 total in column B. Chips say all three agree, confidence 0.97, 7 sources, corpus 2026-Q3 v2. On the form beside it, 10.b is lit and item 8, the line people pick because the lessee is a municipality, is struck with the sentence that rules it out.
“Not here: item 8 says ‘other than leases’.”
- 03One click on a citation
The instruction page, quoted exactly, with its date
Change agentEvery citation opens the page itself: RC-C-20a (12-24), revised December 2024, with “Include all leases to states and political subdivisions in the U.S. in this item.” highlighted. The second layer says what changed since: the page was last revised before Corvane's memo, and the March, June and September 2026 supplemental instructions do not mention item 10. No change.
“Quoted exactly · Citation check.”
- 0409:44
The bank's own precedent, then saved to the working papers
Marcus Oyelaran · Line-of-Business Finance PreparerThe third layer is Corvane's memo PM-2025-031 v1, approved by Gareth Lindqvist on Dec 15, 2025, and what was filed in item 10.b: $228.4M in Q4 2025, $231.9M in Q1 2026 and $236.2M in Q2 2026. The ledger check shows accounts 14520 and 14525 mapped to RC-C 10.b and HC-C 10.b, up $4.4M on Q2. Marcus saves the answer to WP-RCC-26Q3, the RC-C working papers, with the source versions it rested on.
- 0510:04
When the memo and the instruction disagree, the answer says so
Dana Whitcomb · Regulatory Reporting AnalystDana asks whether the $1.18 billion of capital call facilities to 41 private equity funds still go in item 4, as memo PM-2023-019 says. Item 9.a, page RC-C-17 (12-24), now names them, and Corvane has filed them in item 9.a since Q4 2024, but the memo, approved in March 2023, was never changed. The verdict line is replaced by one plain sentence, at confidence 0.62.
“The three sources disagree. The instruction says item 9.a; memo PM-2023-019 says item 4; Corvane has filed item 9.a since Q4 2024.”
- 0610:05
Packaged for the Policy Lead, with a clock
Routing agentThe Routing agent sends the question to Renata Kowalczyk with the three passages and the filed values from Q4 2024 to Q2 2026. Inside the filing window her clock is one business day: due Oct 23, 12:00. Two minutes later it marks Q-26Q3-0436, on subscription lines, as a likely duplicate. Her queue holds 9 open questions; 3 are past 75% of their clock, and the manager has been told.
- 07The ruling
She rules once, with a reason code, for both questions
Renata Kowalczyk · Regulatory Reporting Policy LeadRenata sees the three sources side by side and edits the drafted ruling: RC-C item 9.a and Memorandum item 10.c, and on the FR Y-9C, Schedule HC-C item 9.a. She picks RL-03, “Instruction changed; memo updated”, and applies it to the duplicate too. Nothing filed changes. The Memo agent drafts PM-2023-019 v2 as a redline.
The Routing agent never rules, and the Memo agent never approves or publishes.
- 08Maker and checker
The manager approves v2; the maker cannot
Gareth Lindqvist · Regulatory Reporting ManagerThe redline strikes item 4, Commercial and industrial loans, and inserts item 9.a and Memorandum item 10.c, with the basis quoted from RC-C-17 (12-24) and ledger account 13310 now mapped to item 9.a. Acting as Renata, the Approve button is disabled with the reason shown. Gareth approves v2, and only then is it written back to the memo library.
“Approves or returns with a reason, cannot be the maker.”
- 09Right after
Every answer that cited the old memo, re-checked
Change agentThe Change agent re-checks the 9 saved answers that cited PM-2023-019 v1: none to amend. Its revision-date watch lists the 6 of 180 memos that rely on a page revised after they were approved: 5 cite a passage that changed, each with a re-check to open, and one cites a passage that did not, which Renata reviewed on Oct 5. The September 2026 supplemental instructions, read Oct 2, affect no memo.
- 10On the record
What the preparer was told, from which page, on which day
Simone Achterberg · Internal AuditEvery question, answer, ruling, approval, export and setting change is on the audit trail with who, when, why and the evidence, people and agents alike, kept seven years. The examiner pack holds each answer with its three layers and source versions, the rulings with reason codes, memo versions with maker, checker and redline, and the agent, prompt and model versions of the day. Simone reads everything and decides nothing.
“Customer and borrower names typed into questions stay masked in the pack. The pack is watermarked with the requester and logged.”