Agents in Financial Services
Adoption, customer-facing risk, model error rates, and the rules already in force
Executive summary
Three quarters of UK financial firms already use AI, a third say they fully understand the systems they run, and more than a third of the US population has dealt with a bank's chatbot. Against that, a tribunal has held an airline liable for its chatbot's advice, a finance question-answering benchmark found a frontier model wrong or silent on four questions in five, and the EU has classified credit scoring as high-risk. This report puts the numbers together and sets out controls a risk function can sign off.
Key findings
- Adoption is ahead of understanding. In the 2024 Bank of England and FCA survey, 75% of firms used AI and a further 10% planned to, while 34% reported complete understanding of the AI they use and 46% partial.
- The customer-facing surface is large. By 2022, about 37% of the US population, over 98 million people, had interacted with a bank's chatbot, and all ten of the largest US commercial banks had deployed one.
- A chatbot's statement binds the firm. A British Columbia tribunal found Air Canada liable for negligent misrepresentation by its website chatbot and awarded the customer $650.88; the airline's argument that the chatbot was a separate entity was rejected.
- Frontier models get finance questions wrong at scale. On FinanceBench, GPT-4-Turbo with a retrieval system incorrectly answered or refused 81% of questions; in a separate study, models hallucinated on 58% to 88% of verifiable legal questions and could not reliably predict their own errors.
- The rules are already written. The EU AI Act lists creditworthiness assessment and life and health insurance pricing as high-risk uses, and SR 11-7 has required validated, documented, and monitored models in US banking since 2011.
Cite this report
Arcifa, R., & Carra, F. (2026). Agents in Financial Services. Montana Research Foundation report MRF-R-2026-03. https://montanaresearch.org/reports/mrf-r-2026-03/
BibTeX
@techreport{arcifa2026agents,
title = {Agents in Financial Services},
author = {Arcifa, Ricardo and Carra, Francieli},
institution = {Montana Research Foundation},
type = {Insight report},
number = {MRF-R-2026-03},
year = {2026},
month = {8},
url = {https://montanaresearch.org/reports/mrf-r-2026-03/},
note = {PDF: https://montanaresearch.org/reports/mrf-r-2026-03.pdf}
}