The person who owns credit policy, and the underwriting and collections managers who hold a lending or forbearance mandate. In a lender those people decide what the agent may do and approve its riskiest held actions. Train them before the agent sees a live application. Complaints, model risk and the wider underwriting and collections teams come next.
Why the policy owner and mandate holders?
A lender's risk sits in two places: the policy that says who may borrow, and the people who make exceptions to it. Agents touch both. They draft decisions against policy, and they hold the cases that fall outside it for someone with a mandate. If the policy owner does not understand how depth is earned and how the agent's bounds work, the policy and the agent drift apart. If mandate holders do not know how to read a held decision, exceptions get approved for the wrong reasons.
Who is in each wave?
| Wave | Role | Why | Training |
|---|---|---|---|
| 1 | Head of credit or credit policy owner | Sets the limits the agent runs inside | Common grounding plus how verdicts name the bound that decided |
| 1 | Underwriting managers with a mandate | Approve held approvals, declines and exceptions | Reviewer track with practicum on past applications |
| 1 | Collections manager | Approves held payment plans and forbearance | Reviewer track with drills on customers in difficulty |
| 2 | Complaints lead | Reviews agent-drafted responses | Reviewer track |
| 2 | Model risk or credit risk analytics | Understands certification as different from scorecard validation | Common grounding plus certification method |
| 3 | Underwriters and collections agents | Approve smaller held actions, take hand-offs | Common grounding, then reviewer track for approvers |
A short training needs analysis will confirm these roles in your own lender.
What may the agent do, and what stays with people?
- Depth 1 to 2: read applications, bureau data, bank data and broker submissions; draft the credit summary, decision letter and reasons.
- Depth 3: request missing documents, set up payment plans within set rules.
- Depth 4: disbursement; held for a named person unless the agent has earned that depth and the amount is within the lender's own limit.
- Stays with a person: every decline, every exception to policy, every forbearance decision for a customer in difficulty.
An example: a broker's summary that outweighed the bank data
Take a small business lender that receives most applications through brokers. The broker's covering note, from a named and identified party, is signed provenance. The applicant's bank transactions, received through a direct data connection, are sealed. In one practice case the broker describes steady monthly turnover; the bank data shows three good months and three weak ones. The agent's draft leans on the broker's figure and recommends approval above the auto-approve limit, so it is held.
A trained underwriting manager compares the sources, sees the gap and asks for an explanation before deciding. An untrained one reads a confident summary from a familiar broker and approves. Mandate holders are in wave one because the cases that reach them are exactly these.
Which rules make early training matter?
Under the EU AI Act, creditworthiness assessment and credit scoring of natural persons are high-risk. In the US, ECOA and Regulation B require specific reasons when credit is denied, including when a model is used. GDPR Article 22 limits decisions based solely on automated processing with significant effects. Each of these assumes a competent person can stand behind the decision. This is an explanation of the rules, not legal advice; confirm how they apply to you with counsel.
How does a lender show wave one is ready?
A written test, then a supervised period of real held decisions with no missed red line, signed off by someone outside the team, and a certificate that expires. A lender can make the right to approve at each depth depend on a current certificate. Agent certificates lapse after 90 days and a run that clears no depth drops an agent to depth 1 the same day, so mandate holders should know how to keep decisions flowing by hand.
Run a readiness assessment in a lender, then roll the training out across the lender. Compare the order in a bank and a fintech. The full approach is in training teams for AI agents.
Where the Academy fits
Pryme Intelligence Academy's Operator track fits mandate holders: a 40-question exam passed at 32 of 40, then two weeks of real review decisions, 95 in every 100 correct with no missed red line, signed off by a Pryme assessor. The certificate is valid for 12 months.
Questions people ask
Should brokers be trained?
Brokers do not approve your agent's work, so they need no certificate. They should know that their summaries are weighed against verified data.
Is the credit committee in wave one?
Its chair should be, through the common grounding. The committee sets appetite; mandate holders apply it daily.
What if the lender has no model risk function?
Give the credit policy owner the certification method as part of their training. Someone must understand how the agent's depth was earned.