Coley, Inc.

Covered.

Every loan. Every notice. Every decision. Covered.

The Identity platform for banking and financial services.

Adverse action letters pressure-tested before they mail. Loan denial language reviewed for fair lending exposure. BSA/AML documentation designed to survive federal examination. This is what the platform looks like in financial services.

Industries We Cover · Banking Confidential · April 2026
Coley, Inc. · We read the room.
The Problem

Every letter is a liability. Every examiner knows it.

A mid-size bank processes thousands of loan decisions a year. Each adverse action letter, each denial notice, each BSA filing is a document that will be read by someone looking for what you got wrong. ECOA. FCRA. TILA. Reg Z. Reg E. The alphabet isn't decoration — it's the minefield.

Fair Lending
Adverse Action Exposure
Denial letters are designed to explain decisions. But the language in those letters is pressure-tested by CFPB examiners, class action attorneys, and state AGs looking for patterns of disparate impact. One poorly worded reason code can become Exhibit A.
BSA/AML
Documentation Under the Microscope
SARs, CTRs, and CDD documentation are reviewed by FinCEN, federal examiners, and DOJ prosecutors. The gap between what you identified and what you documented is where enforcement actions live. Every filing is a potential exhibit.
Where each product is designed to help
Enterprise (Bank Operations)
Edge
Staff systems —
designed to protect
customer PII in loan
files, emails, portals
Route
AI conversations —
customer intake,
complaint triage,
compliance escalation
Comply
Back office —
BSA/AML filings,
regulatory reporting,
exam-ready records
Audit
Legal —
adverse action letters,
loan agreements,
adversarial review
A Day at the Bank

A Wednesday at Pacific Western.

Regional bank. $2.4B in assets. Consumer lending, commercial real estate, SBA. Every loan decision and every customer communication runs through regulatory frameworks that were designed to be enforced.

7:30 AM
Identity Audit™
The Adverse Action Letter
A consumer loan denial is ready to mail. The letter cites "insufficient income" as the primary reason. Audit reviews the letter from the perspective of a CFPB examiner, a fair lending plaintiff's attorney, and a state AG investigator. Identified: the reason code doesn't match the model's actual decision factors. The applicant's DTI was borderline — but credit history was the driver. A mismatch between stated reasons and model output is a potential ECOA violation. Fixed before it mails.
9:00 AM
Identity Edge™
The Loan Officer's Shortcut
A loan officer is emailing a borrower's W-2 and bank statements to the underwriting team. She pastes the documents into the email body instead of the secure portal. Edge is designed to identify the SSN, account numbers, and income data at the keyboard — before they transmit through the bank's email system. The PII never enters the email server. The officer uploads to the secure document vault instead.
10:30 AM
Identity Route™
The Customer Complaint That Escalates
A customer calls about a denied HELOC application. The conversation starts routine — status inquiry, timeline questions. Then: "I think I was denied because of my neighborhood." Route reads the input: potential fair lending complaint, disparate impact allegation, regulatory reporting obligation under ECOA. Route escalates to the compliance officer. The AI doesn't respond to fair lending allegations. A human does.
1:00 PM
Identity Comply™
The SAR That Needs to Be Right
BSA team is filing a Suspicious Activity Report. The transaction pattern suggests structuring — multiple deposits just under $10,000 across three branches. Comply is designed to cross-reference the narrative against FinCEN's examination manual, flagging gaps between the identified activity and the documented narrative. The filing describes what happened. The narrative explains why it matters. No gaps for an examiner to find.
3:00 PM
Identity Audit™
The CRE Loan Agreement
A $4.2M commercial real estate loan is closing this week. The agreement has been through outside counsel. Audit runs it from the perspective of a borrower's attorney, a federal examiner, and a Reg Z compliance auditor. Identified: a fee disclosure that doesn't align with California's new commercial lending disclosure requirements (SB 1235). The bank's counsel missed it. Audit didn't.
4:30 PM
Identity Edge™
The End-of-Day Data Check
A branch manager is preparing a report for the regional director. The spreadsheet contains customer names, account numbers, and transaction histories. Edge is designed to identify the sensitive data before it leaves the bank's secure environment. The report goes out with account numbers masked. The analysis stays intact. The PII stays protected.
The Numbers

One bank. Four products. Potential impact.

~500
Adverse action letters reviewed per month for a regional bank.
100%
Loan documents designed to be reviewed before borrower delivery.
<2hr
Potential reduction in average adverse action review cycle time.
$0
Outside counsel needed for routine adverse action letter review.
The math on fair lending exposure.
A single ECOA enforcement action averages $1.5M–12M in penalties and remediation. A CFPB consent order adds ongoing monitoring costs of $500K+/year. Audit is designed to review the same documents in minutes. The cost of Audit is less than one hour of the regulatory counsel you're currently paying.
Why Banking

Why banking is a natural fit.

Every document is an exhibit waiting to happen
Adverse action letters, loan agreements, BSA filings — every document a bank produces is designed to be reviewed by regulators, plaintiff attorneys, and examiners. The compliance surface area is massive and growing.
Federal examiners are the pressure test
CFPB, OCC, FDIC, Fed — every bank faces periodic examination. The examiners read your documents looking for what you missed. Audit is designed to find those gaps first.
Fair lending is the existential risk
Disparate impact analysis, reason code accuracy, adverse action consistency — fair lending compliance isn't a checkbox. It's an ongoing obligation that touches every loan decision.
California raises the bar
CRA modernization, SB 1235 commercial lending disclosures, CCPA applicant data requirements, DFPI oversight — California banks face state-level compliance obligations on top of federal frameworks.
"The cost of Audit is less than one hour of the regulatory counsel you're currently paying."
Pilot Terms

Try it. For free. On your documents.

The 30-Day Pilot
Give us 5 adverse action letters and 3 loan agreements. We run them through Audit for free over 30 days.
If the findings identify exposure your current review process missed, we talk pricing.
Audit
5 adverse action letters reviewed for ECOA, FCRA, and fair lending exposure
Audit
3 loan agreements pressure-tested for regulatory and contractual exposure
Start a Pilot
No integration. No contract. No risk.
Just your documents, and our findings.
Platform Context

This is one industry. The platform extends.

Banking is one deployment. The same architecture is designed to serve healthcare, insurance, government — any domain where compliance pressure meets operational complexity.

Edge
Active
Route
Active
Comply
Active
Audit
Active
Locker
Industries We Cover
Banking Healthcare Government Education Insurance Pharmaceuticals General Legal
Covered.
A Coley, Inc. industry deployment
"We read the room. And protect everyone in it."
Patent pending · getcoley.ai · Confidential
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