How to keep credit analysts ready for an AI agent’s 90-day recertification

Brief analysts on three things each cycle: what the agent now spreads and drafts, which sources it trusts, and what it refuses. Every 90 days the credit agent is recertified on your own files, so its depth on spreading financials or drafting memo sections can move. Analysts who know the delta check the right numbers; analysts who do not, check everything or nothing.

What does recertification change for a credit analyst?

The agent's work sits underneath the analyst's judgement. At depth 1 it reads financial statements, bureau data and the existing exposure. At depth 2 it spreads the statements into the bank's template, calculates ratios, checks covenants and drafts sections of the credit memo. It does not approve credit at any depth. The decision, and the reasons for it, stay with the analyst and the credit committee.

Recertification re-runs the agent's cases on recent applications and reviews. The grounded gate carries most weight here: every figure in a draft memo must trace to a source. Changes that reach the analyst's desk include the agent dropping a depth for a statement format it struggles with, a new source being added, or a memo section the agent no longer drafts.

Provenance shapes the work. Audited accounts come from a named, identifiable auditor and are signed. Management accounts supplied by the borrower are declared. Bureau data is signed by the bureau. A ratio built on declared numbers is still useful; the analyst just needs to know that is what it rests on. A short refresher on the idea is in what recertification is.

Who owns the cycle?

The head of credit analysis owns analyst readiness. The builder owns recertification. Credit risk owns the policy the memo must follow. Where lending is to individuals, model risk or compliance should also see the change note, because creditworthiness assessment of natural persons is listed as high-risk in Annex III of the EU AI Act, and in the US ECOA and Regulation B require specific reasons when credit is denied, including when a model is used.

The steps for each cycle

1. Agent, depth 1: report the cycle. Files spread, memo sections drafted, figures the analyst changed, refusals and the deciding bound for each.
2. Person (senior analyst): sample spreads. Re-spread a small sample by hand and compare.
3. Person (builder): recertify on recent files, including formats the sample found difficult.
4. Person (head of credit analysis and builder): write the change note: statement formats now held for manual spreading, new or removed sources, memo sections that changed.
5. Agent, depth 2: draft two practice files showing the changes, anonymised and checked by the senior analyst.
6. Person (head of credit analysis): brief analysts using the practice files; each analyst marks which figures they would verify and why.
7. Person (each analyst): confirm they have read the note.
8. Person (senior analyst): review the first ten memos drafted under the new certificate.

What should analysts retrain on?

Where the agent struggles. If recertification found the agent unreliable on group accounts or on a particular accounting standard, those files now arrive for manual spreading. Analysts need to know which and why.

Tracing figures. Every figure in a draft memo should link to its source. Analysts should practise tracing two or three key numbers per memo, starting with debt and earnings.

Declined applications. When a person is declined, the reasons must be specific and true. The agent can draft wording from the analyst's decision, but the analyst confirms that the reasons are the real ones.

Refusals. If the agent refused to draft a section because a source was missing, the right move is to get the source, not to write around the gap.

Controls and the evidence they leave

• Hand re-spread sample. Evidence: the sample and variances found.
• Change note. Evidence: the dated note, seen by credit risk.
• Analyst confirmation. Evidence: named sign-off per cycle.
• First-ten memo review. Evidence: the review notes.
• Practicum for analysts new to the agent. Evidence: the practicum log template for credit analysts.

Pryme Intelligence Academy's Operator track, with module tests set in the learner's own industry and role, gives analysts a checkable certificate that sits alongside these records.

What to measure

Variance between agent and hand spreads in the sample. The number of memo figures analysts changed, by section. And the time from file receipt to memo, before and after the cycle. If analysts change more figures after a cycle, read the change note again: it may have missed something the agent now does differently.

Where does it slip?

Analysts stop tracing because the agent is usually right. One misread statement then reaches committee. The review of the first ten memos after each cycle exists to catch this.

Formats change without notice. A borrower switches accounting standard, the agent's spread drifts, and nobody connects the two. Make "new statement format" a standing item on the cycle report.

The analyst signs a memo they did not write. The view remains theirs, as are credit analysts accountable for an AI agent's mistakes explains. Teams nearby run similar cycles; compare keeping credit controllers ready, keeping fraud analysts ready and the guide to AI literacy and certification for people who work with agents.