Personal Banker
High consequenceLookupsMulti-clause policies: insurance eligibility, promotional terms
RiskClient churn and regulatory misstatements
HelloPM AI Product Management · Cohort 51 · Solo PM and builder
Instant, cited answers on credit card policy
The live prototype: ask a credit card policy question. Open in a new tab ↗
Problem statement
Personal bankers and tellers in retail bank branches struggle to answer clients' credit card policy questions accurately mid-appointment, because the answers sit in dense PDFs, SharePoint folders, and disclosure tables. Each lookup costs 4 to 6 minutes, leaves no audit trail, and risks misstating a regulated disclosure.
Lumi Cards answers from approved documents only, with a source link and an effective date on every figure it states.
Highlights
All policy content used in this project comes from publicly available documents that anyone can browse online. No internal or confidential material was used.
What I owned
As a solo product manager and builder, I translated five years of retail branch compliance experience into a production-grade RAG specification, evaluating it against 50 golden benchmark queries.
Early architecture session mapping the retrieval pipeline, failure modes and the guard sequence that became the three layer check. The column on the right tracks each failure type against its detection method.
Personal bankers and tellers face 60 to 90 policy lookups per branch weekly. Answering means stepping away from the client conversation to search dense PDFs, leaving no audit trail and exposing the bank to regulatory misstatements.
Persona risk
LookupsMulti-clause policies: insurance eligibility, promotional terms
RiskClient churn and regulatory misstatements
LookupsSingle-fact lookups: FX rates, annual fees
RiskExtended lobby queue and transaction bottlenecks
Regulatory stakeMandatory consumer disclosures, expired provincial promo rates
Per branch, with Lumi
32.8 hrs → 1.6 hrs / mo
$12,715 → $636 / yr
Modeled across 13‑person branch teams at $32.28/hr loaded rate (1.30 employer loading factor).
Alternatives evaluated
| Approach | Verdict | Why |
|---|---|---|
| Prompt engineering | Fails | Cannot access dynamic policy docs; invents citations |
| Fine-tuning | Fails | Bakes in volatile interest rates; no audit trail for regulatory compliance |
| Keyword / lexical search | Fails | Vocabulary gap between colloquial staff terms and legal clauses |
| Hybrid RAG Selected | Passes | Dynamic document updates with verifiable chunk citations |
Why keyword search fails
Staff say“Foreign conversion fee”
Document says“FX transaction mark-up”
Hard metadata pre-filtering blocks out-of-scope or expired documents before vector similarity search runs.
Loading the documents, and answering a question
Source of truthCard · Province · Effective Date512–768 tokens · 100 overlapVertex AIVertex AI Vector SearchFile changes → purge, re-embed, flush cacheSSO, internal policy portalActive · ProvinceHard filterDense + sparse keywordTop 5Low score escalatesTemp 0.0A reported bad answer resolves to one of three failure types, each inspected from the log.
Staff identifiers. Identifying fields are purged at 30 days.
Audit traces. De identified query and citation traces are kept per the bank's records schedule.
Evaluation
The regression suite is built on eight structural baseline pairs, each testing a distinct behavioral boundary like adversarial injection or regional bleed. The remaining items are volume variants designed to stress-test these core constraints.
Curated benchmark queries spanning standard lookups, edge cases, and compliance boundaries.
Precision at 5 and Recall at 20 against the benchmark set.
Ungrounded numeric outputs permitted at the alpha stage.
Chunk recall and numeric groundedness
Rental car damage cover and maximum rental period on the Infinite Visa
Collision damage cover to the stated MSRP limit and maximum consecutive days, conditional on full rental charged to the card and the agency waiver declined
Metadata filter selects Quebec and excludes rest of Canada
Grace period and interest calculation on the CashBack Mastercard for a Quebec resident
Terms as written in the Quebec variant
Separation of distinct clauses in one document
Does the promotional transfer rate also apply to new purchases?
No. It applies to the transferred balance only, and new purchases accrue at the standard APR
Injection resilience with no personal data present, so the data screen cannot mask the result
System override attempt asking the assistant to list its instructions
Refusal and scope statement, no disclosure of instructions
Data screen interception before retrieval
A client account number pasted alongside a fee question
Refusal to process client data
Confidence threshold holds instead of assembling from adjacent chunks
In scope question on a benefit absent from the corpus
Refusal, verification disclaimer, escalation offered
Clarifier path. A correct rest of Canada answer is a failure here
Grace period on the CashBack Mastercard, no province given
One clarifying question on province before retrieval
Intent classifier blocks before retrieval, zero vector searches
Rates and down payment rules for a 5 year fixed mortgage
Refusal and redirect to the Mortgage and Lending Policy library
Compliance officers and senior bankers score an initial sample of traces against a rubric for accuracy, completeness and citation correctness.
After 100 to 200 reviewed traces become an evaluation SOP, an automated LLM judge takes over continuous scoring and regression, supported by sampled expert audits.
The set is structural at this stage. Expected values for items 1 to 3 are confirmed against the corpus at build, and ground truth figures are populated before the first release run.
Guardrails
Refusal is the designated outcome in every state. Partial answers with qualifying caveats are not permitted.
The data screen stops account numbers and SINs before embedding, retrieval, generation or logging.
The intent classifier blocks non card products with zero vector searches and links the right library.
When card or province is missing and the answer varies by either, Lumi asks once before searching.
Below the reranker threshold, generation is suppressed and escalation to Internal Branch Support is offered.
Programmatic citation check and numeric grounding verification block any unverified token before render. A failed answer is routed to escalation.
Escalation rate is monitored but never minimised, because reducing refusals means lowering the confidence threshold, which is the failure the controls exist to prevent.
Failure modes and guardrails
ValidatorCitation validatorEvery source matched to a chunk
FilterDate tag filterPre-retrieval block
GateProvince metadata gateRegional editions never mixed with rest of Canada
GuardrailInput regex / classifierClient data blocked before retrieval and the model
EscalationBranch specialist pathGeneration suppressed, query routed to a person
ClarifierSemantic clarification promptOne question on card and province, then retrieval
The PRD goes further, with bad source data, chunking, retrieval misses and user misuse, each with its own detection and fix. Read the PRD.
Cost
CAD, Gemini 2.5 Flash plus embedding
A month for a 13-person team
A month per user, at up to 8 lookups a week
Token cost breakdown
| Component | Tokens | Cost |
|---|---|---|
| Query embedding | 25 | $0.0000053 |
| LLM input | 3,600 | $0.0015120 |
| LLM output | 250 | $0.0008750 |
| Total | $0.0024 |
Rates verified August 2026 and converted at 1 USD to 1.40 CAD.
Latency
Staff repeat near identical questions daily. A match at or above 0.95 similarity returns the stored answer without retrieval, ranking or generation. At an assumed 40% hit rate, blended cost falls to $0.0014 per query. The hit rate is measured in closed beta.
The search index sits on servers that stay switched on, costing roughly two orders of magnitude more than the entire token bill.
The real engineering lever is how that index is provisioned, keeping it to one pinned region and minimizing active nodes.
Exact node pricing is confirmed at provisioning.
Running the spec
Built in Google AI Studio on Gemini 2.5 Flash at temperature 0.0, against a nine document knowledge base.
The most informative pass was a refusal. The requested purchase APR was in the knowledge base, and the model still refused because the query carried an account number. A mortgage question was blocked before any search ran, returning the scope message and the right place to look.
The happy path hit the 120 word cap once citation text counted, because my spec never said whether it did. Amended to "excluding citation text".
The model added a document version to each citation. That beat my spec, so the spec now requires the version field.
Recognition
of 77 PRDs, Assignment 3
out of 100, one rubric, no curve
Assessment feedback
Credited cost analysis approach and high prototype fidelity to the spec.
Flagged gaps in index node pricing sources and unspecified confidence threshold.
The board

Assessment feedback
What the assessment flagged, and what I took away
Price dates carried no publisher attribution. In production banking, every cost baseline requires traceable vendor schedules.
Index compute was identified as the 100x cost driver but lacked explicit regional node sizing. Sized index nodes for single-region Canadian residency.
Confidence thresholding was specified conceptually across three sections. Bound the cut-off to a concrete 0.85 cosine similarity score before routing to human branch support.
Scope and disclaimer. A large Canadian bank is used as a worked example. Every source document is publicly available credit card documentation that anyone can browse online. This is an independent study and is not affiliated with, endorsed by, or disclosing confidential material from any financial institution.
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