CLARITY Act · Senate Calendar No. 423 — House-passed 17 July 2025, awaiting Senate floor time. We plan on the regimes that bind today.
What governs nowTwin against twin.
A live institution twin, continuously compared to a live regulator twin. The delta is the product — signed, dated, and defensible in a supervisory meeting.
You choose the AI. Cabier orchestrates the trust.
The six twin surfaces
Every obligation, both sides of the table.
The Regulator Digital Twin runs continuously across the six-capability spine. Each surface pairs what the institution can evidence with what the regulator expects — and surfaces the delta before a supervisor does.
Surface
Operational Resilience
Institution twin
DORA impact tolerances, RTO/RPO, tested severe-but-plausible scenarios
Regulator twin
EBA/PRA/OSFI E-21 expectations, published thresholds, peer-cohort medians
Delta signal
Tolerance drift, untested scenarios, cohort outliers
Surface
AI Governance
Institution twin
AI system registry, PSI/CSI drift, human-override rate, red-team results
Regulator twin
EU AI Act Art. 55, SR 11-7, OSFI E-23, NIST AI RMF profiles
Delta signal
Undeclared GPAI use, stale model docs, missing accountable executive
Surface
Financial Crime
Institution twin
SAR volume, false-positive rate, alert-to-file cycle time
Regulator twin
FinCEN / FCA / FINTRAC typology packs, sector benchmarks
Delta signal
Typology coverage gaps, cycle-time outliers, weak governance narrative
Surface
Cyber & Third Party
Institution twin
KEV exposure, patch SLA, TPRM tier-1 concentration, cloud region posture
Regulator twin
CISA KEV, SEC 8-K Item 1.05 posture, NIS2 Article 23, OSFI B-10
Delta signal
Unremediated KEV, undisclosed material incident, concentration above threshold
Surface
Conduct & Consumer
Institution twin
Consumer Duty outcomes, complaint trend, vulnerable-customer flags
Regulator twin
FCA outcome expectations, peer-cohort complaint distributions
Delta signal
Outcome underperformance vs cohort, unresolved complaint clusters
Surface
Tokenisation & Reserves
Institution twin
Reserve attestations, redemption SLAs, proof-of-reserve cadence
Regulator twin
GENIUS/CLARITY substantial-similarity, MiCA Art. 36, MAS/HKMA reserve rules
Delta signal
Attestation staleness, redemption SLA breach, disclosure gap
How the twin runs
Four-step spine, same evidence set.
1 · Ingest
Institution twin is built from CCM feeds, evidence vault, control-as-code output, and live ORS telemetry. Regulator twin is built from published rules, supervisory statements, dear-CEO letters, enforcement patterns, and peer-cohort medians.
2 · Compare
Continuous diff across the six-capability spine. Each obligation is scored institution-side vs regulator-side with a delta, a directional trend, and a materiality tag.
3 · Score
Deltas feed ORS. Trust Gates block execution when a live obligation drifts beyond tolerance. Board pack, regulator brief, and audit ID are generated from the same evidence set.
4 · Attest
Named accountable executives sign the delta narrative each cycle. The signed attestation is the artefact the regulator receives — not a self-graded RAG.
Guardrails