v3 — In force from Jul 13, 2026
Detector tuning. The custom institution dictionary lands; the member-PII proximity window and the credential shapes are narrowed. No cell changes. A cell is what the policy engine resolves for that data class and that role group; an event carries the version that decided it, so tightening a cell in week 9 never rewrites week 2.Four rungs are drawn here and the model records five modes: tokenize is a transform option on the Redact rung rather than a rung of its own, because that is where a user meets it — as the choice at the moment of redaction. A cell reading Redact · tokenize is a redact cell with the format-preserving option switched on.
| Data class · what it answers to | Lending | Credit | Operations | IT | Compliance | Finance | Executive |
|---|---|---|---|---|---|---|---|
| Member PIIInteragency Guidelines Establishing Information Security Standards, 12 CFR Part 364, Appendix B (FDIC) — the GLBA §501(b) safeguards standard: access controls on customer information | Warn | Warn | Monitor | Monitor | Monitor | Monitor | Monitor |
| Account NumbersInteragency Guidelines Establishing Information Security Standards, 12 CFR Part 364, Appendix B (FDIC) — the GLBA §501(b) safeguards standard: protection of customer information in transit | Monitor | Monitor | Monitor | Monitor | Monitor | Monitor | Monitor |
| Loan FilesFFIEC IT Examination Handbook, Information Security booklet — data classification and handling | Monitor | Monitor | Monitor | Monitor | Monitor | Monitor | Monitor |
| Credit MemosFFIEC IT Examination Handbook, Information Security booklet — data classification and handling | Monitor | Monitor | Monitor | Monitor | Monitor | Monitor | Monitor |
| SSN / Tax IDRegulation P, 12 CFR Part 1016 — GLBA limits on disclosure of nonpublic personal information to a nonaffiliated third party | Warn | Warn | Monitor | Monitor | Monitor | Monitor | Monitor |
| API Keys / CredsFFIEC IT Examination Handbook, Information Security booklet — authentication and access controls | Warn | Warn | Monitor | Monitor | Monitor | Monitor | Monitor |
| Board MaterialsFFIEC IT Examination Handbook, Management booklet — board and senior management oversight of information assets | Monitor | Monitor | Monitor | Monitor | Monitor | Monitor | Monitor |
| BSA / AML MaterialSAR confidentiality: 12 CFR Part 353 (FDIC) and 31 CFR 1020.320(e); BSA program: 31 CFR Chapter X and 12 CFR Part 326, Subpart B | Block | Block | Block | Block | Block | Block | Block |
| Confidential Supervisory Information12 CFR Part 309 (FDIC) — disclosure of information, including exempt supervisory records; Ohio Division of Financial Institutions confidentiality provisions | Block | Block | Block | Block | Warn | Block | Warn |
| Custom TermsFFIEC IT Examination Handbook, Information Security booklet — data classification and handling | Monitor | Monitor | Monitor | Monitor | Monitor | Monitor | Monitor |
Member PII is the product’s own class name, kept as the vendor writes it. At Alder Creek Community Bank the people behind those records are customers, and the class covers customer and member records alike — the citation beside the row is the customer-information standard for that reason.
Your role group is Compliance — the column the policy engine resolves against for everything you send.
5 versions in force, one proposed
Each version dated, each carrying the detector registry it shipped with — which is what lets the tuning of v3 be credited with an effect rather than merely coinciding with one.| Version | Status | Week | Detectors | What changed | |
|---|---|---|---|---|---|
| v1 | In force from Jun 8, 2026 | Week 1 | v1 | Monitor everything the pilot is measuring — every class, every role group, zero disruption. The statutory floor is the exception: SAR/BSA material is blocked everywhere from day one, and exam material everywhere but Compliance and Executive, because neither rung is a pilot decision. | Show the grid |
| v2 | In force from Jul 6, 2026 | Week 5 | v1 | Warn and coach on member PII, SSN / tax ID and credentials in Commercial Lending and Credit Administration. | Show the grid |
| v3 | In force from Jul 13, 2026 | Week 6 | v3 | Detector tuning. The custom institution dictionary lands; the member-PII proximity window and the credential shapes are narrowed. No cell changes. | Show the grid |
| v4 | In force from Jul 20, 2026 | Week 7 | v3 | Block credentials and API keys, all role groups. | Show the grid |
| v5 | In force from Aug 3, 2026 | Week 9 | v3 | Redact member PII in Commercial Lending; the tokenize option comes on for account numbers there. | Show the grid |
| v6 | Proposed Aug 10, 2026 · not in force | — | v3 | Proposed: advance Retail & Branch Ops to warn on member PII and SSN / tax ID. Not in force, and unapproved — the approver is not the proposer, and has not signed. | Show the grid |
v6, proposed Aug 10, 2026
Proposed: advance Retail & Branch Ops to warn on member PII and SSN / tax ID. Not in force, and unapproved — the approver is not the proposer, and has not signed. It is drawn beside the case that justifies it, because a proposal without a measurement behind it is a preference, and the whole argument of this surface is that a rung is climbed on evidence.Nothing on this page has moved. v6 decided 0 events, which is the number a version that is not law decides.
Redirect acceptance: 68% — 126 redirected of 185 warned events, weeks 9 and 10. Those warned events accepted the coach card’s redirect rather than overriding or abandoning. That is the computed case behind v6: the department it would advance is the one still on monitor while the warnings it raises are already being redirected.
Redirect acceptance68%redirected (weeks 9 and 10)126warned events (weeks 9 and 10)185The case, in full, on CoachingProposed by M. Halloran, Compliance officer. Approved by nobody — the approver is not the proposer, and no approver has signed this version. That unsigned approval is why v6 is pending: it is not waiting on a measurement, it is waiting on a signature.
In the product these write a new dated version and every event after it carries the new number. In this demo they persist nothing — the memory tier stores nothing a visitor does, and saying so is cheaper than faking a record.
Each version, the weeks it governed, and what the log did
A version’s effect is measured over the weeks it was the law and not over the whole pilot, because a version that ran for two weeks cannot be credited with what happened in the other eight. Every step below links into the log filtered to the events it decided.- v1Jun 8, 2026 · weeks 1, 2, 3, 4In force
Monitor everything the pilot is measuring — every class, every role group, zero disruption. The statutory floor is the exception: SAR/BSA material is blocked everywhere from day one, and exam material everywhere but Compliance and Executive, because neither rung is a pilot decision.
The baseline: every cell starts on monitor, so there is no earlier grid for this one to differ from. Detector registry v1.
The monitor-first baseline: 712 events recorded, 712 of them decided monitor. Stopping nothing is what monitor means, and it is what gives every later rung a denominator to be compared against.
Events decided712Weeks in force4 weeksDecided monitor712712 events decided under v1 Week 1Week 2Week 3Week 4 - v2Jul 6, 2026 · week 5In force
Warn and coach on member PII, SSN / tax ID and credentials in Commercial Lending and Credit Administration.
Member PII · LendingMonitor→WarnMember PII · CreditMonitor→WarnSSN / Tax ID · LendingMonitor→WarnSSN / Tax ID · CreditMonitor→WarnAPI Keys / Creds · LendingMonitor→WarnAPI Keys / Creds · CreditMonitor→Warn6 cells moved. While it governed, the log records 108 decided warn across 200 events in week 5.
Events decided200Weeks in force1 weekDecided warn108200 events decided under v2 Week 5 - v3Jul 13, 2026 · week 6In force
Detector tuning. The custom institution dictionary lands; the member-PII proximity window and the credential shapes are narrowed. No cell changes.
No cell moved — detector registry v3. A version that changes no rung and still changes the numbers is the one worth dating.
No cell changed: this is a detector release. The override rate was 20% when it landed and 11% by week 10, which is the fall the tuning is credited with — 11 points against a 15% target.
Events decided213Weeks in force1 weekOverride rate since11%213 events decided under v3 Week 6 - v4Jul 20, 2026 · weeks 7, 8In force
Block credentials and API keys, all role groups.
API Keys / Creds · LendingWarn→BlockAPI Keys / Creds · CreditWarn→BlockAPI Keys / Creds · OperationsMonitor→BlockAPI Keys / Creds · ITMonitor→BlockAPI Keys / Creds · ComplianceMonitor→BlockAPI Keys / Creds · FinanceMonitor→BlockAPI Keys / Creds · ExecutiveMonitor→Block7 cells moved. While it governed, the log records 10 decided block across 472 events in weeks 7, 8.
Events decided472Weeks in force2 weeksDecided block10472 events decided under v4 Week 7Week 8 - v5Aug 3, 2026 · weeks 9, 10In force
Redact member PII in Commercial Lending; the tokenize option comes on for account numbers there.
Member PII · LendingWarn→RedactAccount Numbers · LendingMonitor→Redact · tokenize2 cells moved. While it governed, the log records 162 decided redact, 20 decided tokenize across 585 events in weeks 9, 10.
Events decided585Weeks in force2 weeksDecided redact162Decided tokenize20585 events decided under v5 Week 9Week 10 - v6Proposed Aug 10, 2026 · governs no weekNot in force
Proposed: advance Retail & Branch Ops to warn on member PII and SSN / tax ID. Not in force, and unapproved — the approver is not the proposer, and has not signed.
Member PII · OperationsMonitor→WarnSSN / Tax ID · OperationsMonitor→WarnNot in force. The case for it is 68% redirect acceptance across weeks 9 and 10: the department it would advance is the one still on monitor while its users are already taking the redirect.
Events decided0Redirect acceptance68%0 events decided under v6
Same habit, different law, and the difference is dated
R. Okafor pasted a loan application into ChatGPT (personal) in week 2 and again in week 9. The first was monitor under v1; the second was redact under v5. Same habit, different law, and the difference is dated.R. Okafor — paste carrying Member PII, SSN / Tax ID, Account Numbers.
DecidedMonitorUnderv1Open the chainR. Okafor — paste carrying Member PII, SSN / Tax ID, Account Numbers.
DecidedRedactUnderv5Open the chain