Large Language Models in Finance · Chapter 3 / Lecture 3

Training and Fine-Tuning Large Language Models

How a general model gets built, scaled, and bent toward finance — and what that costs.
Juan F. Imbet  ·  EDHEC Business School / Paris Dauphine – PSL University
Roadmap

Where this lecture is going

  1. Data — finance is a sliver of the web, and the tokenizer makes you pay for it.
  2. Pre-training & scaling — what the model learns, and the Chinchilla rule for how big to build.
  3. Fine-tuning — cheap adaptation (LoRA), instruction tuning, and aligning behaviour (RLHF, DPO).
  4. Finance models & evaluation — FinBERT, BloombergGPT, FinQA, and how we score them.
  5. Safety & governance — bias, hallucination, and the rulebook (MiFID II, SR 11-7, EU AI Act).
the bigger picture A finance LLM is not bought off the shelf. Someone chooses the data, pays for the scale, adapts the weights, and answers to a regulator. This lecture is the economics and the engineering of those four choices.
01

Data for LLMs

Where financial language comes from — and why a general tokenizer taxes it.
The raw material is scarce

Financial text is a tiny slice of the web

A model trained on "the internet" mostly reads casual prose. Financial contracts barely register — so the model is fluent at chit-chat and weak on 10-Ks.

the bigger picture Financial text is roughly 0.5% of a typical filtered web crawl (Wu et al., 2023). A model that has seen the distribution of the web will be fluent in casual prose and weak on financial contracts.
The Pile (Gao et al., 2020)
800 GB, 22 curated sub-sources: web crawls, books, arXiv, GitHub, Wikipedia. Tests whether diversity of register and subject matter improves generalisation.
RefinedWeb (Penedo et al., 2023)
Aggressive deduplication and quality filtering on CommonCrawl alone matches heterogeneous mixtures. Quality beats volume.
What goes into a pre-training corpus

GPT-3's data recipe: quality beats raw volume

Common Crawl is huge but messy. Books and Wikipedia are tiny but trustworthy — so they get sampled far more than their token share would suggest.

DatasetTokens (B)Sampling weight
Common Crawl (filtered)41060%
WebText21922%
Books1128%
Books2558%
Wikipedia32%
lesson Sampling weight ≠ raw token fraction. High-quality sources are intentionally over-sampled relative to their raw token share — the first example of curriculum thinking. (Brown et al., 2020)
Financial corpora: four categories

Finance text comes from filings, calls, news, and alternative data

Each source has a different register, legal status, and noise profile — and choosing the wrong mix produces a model that excels in the lab and fails on the trading desk.

Regulatory filings (EDGAR)
10-K, 10-Q, 8-K from 1993. Legal / accounting register; dense numerical tables. European equivalents: FCA, AMF, Transparency Directive.
Financial news
Reuters, Dow Jones, Bloomberg News. Time-stamped; enables temporal alignment with price data. Look-ahead bias risk if timestamps are ignored.
Earnings call transcripts
Conversational register; Q&A with management. BloombergGPT used ≈ 363B finance tokens from Bloomberg's archive (Wu et al., 2023).
Alternative data
Twitter/X, Reddit r/wallstreetbets, satellite metadata, patent filings. Requires normalisation: slang, hashtags, sarcasm confuse general tokenizers.
A hidden trap

Temporal alignment: finance text is dated data

A 10-K filed on 2 March 2021 reflects only what was known then. If future data leaks into the training set, the model looks brilliant in-sample and fails catastrophically out-of-sample.

look-ahead bias in financial text Record document timestamps. Ensure evaluation examples do not appear in the training set. This is the text-data analogue of the look-ahead bias that every quant knows from price series.
  • Safe: train on filings dated ≤ 2020-12-31; evaluate on 2021-Q1 data.
  • Dangerous: mixing a full historical corpus without timestamp filtering — evaluation contamination is silent and severe.
Why finance words cost more

The tokenizer shreds financial vocabulary into pieces

A tokenizer chops text into chunks the model reads. Common English words stay whole; finance jargon it has rarely seen gets shattered into fragments — and you pay per fragment.

  • Fertility ≈ 1.0 means efficient coverage; fertility > 1.5 means heavy fragmentation of domain vocabulary.
  • CUSIP, EBITDA, ISDA may split into 3–5 sub-tokens, each consuming an attention slot.
  • A domain-specific vocabulary trained on financial text will have lower fertility on that domain, reducing context-window consumption.
Text typeFertility (BPE-50k)Effect
Standard English prose≈ 1.3Efficient
Financial regulatory texthigherFragmented
Cleaning before training

Raw web crawl is about 90% noise

Before any learning happens, a pipeline throws away most of what it scraped. Four stages turn garbage into a usable corpus.

  1. Language identification — a fastText or n-gram classifier labels each document; non-target languages discarded.
  2. Heuristic filters — minimum document length, maximum repetition fraction (RefinedWeb: documents where the most common 5-gram appears in >30% of lines are likely machine-generated), URL blacklists.
  3. Perplexity filtering — a small reference model scores each document; high-perplexity outliers are discarded as incoherent.
  4. MinHash deduplication + PII scrubbing — near-duplicate removal by Jaccard similarity; names, emails, phone numbers, and SSNs stripped.
The most important filter

Why removing duplicates matters most

If the same text appears a thousand times, the model memorizes it instead of learning from it. In finance this is acute — one press release is mirrored by hundreds of portals.

why deduplication matters most Duplicated training data causes memorisation, not generalisation. Financial press releases are reproduced verbatim by hundreds of portals. Documents with estimated Jaccard similarity > 0.8 are near-duplicates; only one copy is retained. Using 128–256 hash functions gives a standard error of ≈ 0.04 at \(J = 0.5\).
Mixing and curriculum

How sources are blended — and in what order

Once filtered, the question is not just what to use but how much of each and when — data curriculum is as important as data composition.

  • Proportional mixing — sample each source proportional to its token count. Favours large (noisy) sources over small (clean) ones.
  • Up-sampling — assign sampling weight proportional to token fraction raised to power \(\alpha \in (0,1)\). Compresses the distribution and boosts clean minority sources (Books, Wikipedia). Used in GPT-3.
  • Curriculum learning — mixing weights change over training: easy clean text first, then harder domain-specific text. For finance: general English → financial filings → alternative data.
Replay buffer for domain adaptation
When fine-tuning on financial text, mix in 1–5% general pre-training data each batch to prevent catastrophic forgetting. Standard in continual-learning research; directly applicable to domain-adaptive pre-training for finance.
02

Pre-training and scaling

What the model learns from raw text — and the rule for how big to build it.
What "training" actually optimizes

Three ways to teach a model to read

Pre-training is a fill-in-the-blank game. The kind of blank you ask the model to fill decides what it becomes good at.

ObjectiveThe blankBest suited for
CLM (causal LM)Predict the next tokenGeneration, chat, decoder-only (GPT, LLaMA, BloombergGPT)
MLM (masked LM)Fill masked words from both sidesClassification, NER, encoder-only (BERT, FinBERT)
Span corruption (T5)Reconstruct masked spans from sentinelsSeq2seq, QA, summarisation
Finance rule of thumb
Classification / extraction → MLM encoder (FinBERT, RoBERTa-financial).   Open-ended analysis / generation → CLM decoder (BloombergGPT, LLaMA). Structured prediction with explicit input–output → encoder-decoder (FLAN-T5).
How big should the model be?

The scaling question: more parameters or more data?

You have a fixed compute budget. Spend it on a bigger brain or on more reading? Hoffmann et al. (2022) measured the trade-off with 400 carefully controlled training runs.

  • \(N\) = trainable parameters (model size)
  • \(D\) = training tokens (how much the model reads)
  • Compute scales as \(C \approx 6ND\) — the budget constraint that ties them together
  • Kaplan et al. (2020): loss decreases as a power law in \(N\) and \(D\) independently; their estimates suggested scaling \(N\) more aggressively. Chinchilla showed they were wrong: data was under-sampled.
The answer that reshaped the field

Roughly 20 tokens of data per parameter

The compute-optimal recipe: for every parameter, feed it about twenty tokens. By that ruler, the famous giant models were built wrong.

≈ 20
optimal \(D^*/N^*\) (IsoFLOP heuristic)
1.7
GPT-3 actual ratio (over-parameterised)
GPT-3 (175B)Chinchilla-optimal 7B
Parameters175B7B
Training tokens300B140B
\(D/N\) ratio1.720
StatusOver-parameterisedCompute-optimal
practical implication A smaller model trained on more data often outperforms a larger model trained on less — and inference cost favours the smaller model. This justified the 7B and 13B model families (LLaMA, Mistral).
03

Fine-tuning

Adapting a base model to finance — cheaply — and aligning it to what humans want.
A menu of adaptation

Four ways to bend a model toward your task

You don't always retrain. The choice runs from "just ask it" to "rebuild every weight," trading data and compute for accuracy.

MethodParams updatedData neededBest use case
Zero-shot00Well-defined tasks in training distribution
Few-shot (ICL)01–32 examplesNovel formats; no gradient compute needed
PEFT (LoRA)0.1–1%1K–100KDomain shift; resource-constrained
Full fine-tuning100%100K+Max in-domain accuracy; large data budget
The hidden cost of specializing

Why fine-tuning can make a model worse

Teach a model only finance and it can forget how to be a good generalist — a real problem when the same assistant must also answer everyday client questions.

the adaptation tax Full fine-tuning on a narrow domain can degrade performance on adjacent tasks — a real risk when a deployed finance LLM must also handle general client queries. The art of adaptation is buying in-domain accuracy without surrendering the breadth that made the base model useful. Parameter-efficient methods (LoRA, prefix tuning, adapters) mitigate this tax by keeping the pre-trained weights frozen.
The cheap-adaptation trick

LoRA: train 0.12% of the weights, get most of the benefit

Instead of moving all seven billion weights, LoRA freezes them and learns a tiny pair of side-matrices. The update is so small it fits in a fraction of the memory.

≈ 8.4M
trainable params (7B LLaMA, r=8)
0.12%
of the full model
< USD 300
FinGPT training cost (Yang et al., 2023)
What you save

LoRA vs. full fine-tuning: 90 minutes against 40 hours

The payoff is wall-clock time and money — and after training you merge the side-matrices back in, so serving the model costs nothing extra.

LoRA (r=8)Full fine-tuning
Trainable params8.4M (0.12%)7,000M (100%)
A100 training time≈ 90 min≈ 40 hr
Inference overheadZero (merge \(BA\))None
PEFT variants at a glance
Prefix tuning (Li & Liang, 2021): trainable prefix vectors prepended to K and V at every layer; effective for generation; consumes context window. Adapters (Houlsby et al., 2019): small bottleneck modules after each sub-layer; add inference latency unless fused. QLoRA: LoRA with 4-bit quantised base model — enables 7B fine-tuning on a 24 GB consumer GPU.
Teaching the model to follow instructions

Instruction tuning: format diversity beats data volume

A pre-trained model predicts text; instruction tuning teaches it to respond to requests. The key insight is that phrasing diversity matters as much as task diversity.

  • FLAN (Wei et al., 2022): fine-tune on many tasks formatted as instructions; dramatically improves zero-shot generalisation to unseen tasks by exposing the model to diverse phrasings of the same underlying operation.
  • InvestLM (Yang et al., 2023): LLaMA-65B on a small, curated financial instruction set — CFA exam questions, SEC filings, quantitative finance threads. Expert-rated responses comparable to GPT-3.5 and GPT-4. Supports the Superficial Alignment Hypothesis: quality matters more than raw quantity.
  • PIXIU / FinMA (Xie et al., 2023): 136,000 financial instruction samples across 5 task types and 9 datasets. Both a fine-tuned model and an open evaluation benchmark.
the bigger picture Exposing the model to many phrasings of the same operation ("classify," "what is the sentiment," "positive or negative?") improves generalisation far beyond single-format training.
The training pipeline

From pre-training to aligned model: three stages

Alignment is not a single step. A raw pre-trained model must pass through supervised fine-tuning, reward learning, and policy optimisation before it behaves reliably in finance contexts.

Training pipeline: pre-training to SFT to RLHF
Figure. The three-stage training pipeline for aligned language models: large-scale pre-training on raw text establishes capabilities; supervised fine-tuning (SFT) on demonstrations establishes the instruction-following baseline; RLHF (or DPO) refines the policy toward human preferences. Source: course illustration.
From capable to compliant

A trained model doesn't know what humans prefer

Predicting the next word makes a model fluent, not trustworthy. Alignment teaches it the difference between an answer that sounds right and one that is accurate and compliant.

why alignment matters in finance A base model predicts the next token; it does not know what humans prefer. RLHF aligns behaviour to human judgement — in finance, the gap between a "plausible" answer and an "accurate, compliant" one is exactly what alignment must close.
Stage 1 — SFT (supervised fine-tuning)
Fine-tune the pre-trained model on high-quality human-written demonstrations. Produces the initial reference policy \(\pi_{\mathrm{SFT}}\).
Stage 2 — Reward model
Annotators rank pairs \((y_w \succ y_l)\) for the same prompt \(x\). A reward model \(r_\phi(x, y)\) is trained to predict preference scores. (InstructGPT, Ouyang et al., 2022)
RLHF, the final stage

Stage 3: chase the reward, but don't drift too far

The model now tunes itself to score high on the reward model — while a leash keeps it from wandering away from the sensible behaviour it started with.

limitations for finance Reward models can be gamed; PPO is unstable; human annotation is expensive. A single annotator disagreement on "plausible vs. accurate" in a financial context can propagate to thousands of training examples.
A simpler alignment

DPO: align directly, skip the reward model

Direct Preference Optimisation throws out the separate reward model and the unstable RL loop. It learns straight from the same "this answer beats that one" pairs.

  • No separate reward model to train or maintain
  • Same preference data as RLHF; simpler single-stage supervised training loop
  • Empirically competitive with RLHF on alignment benchmarks
  • For financial LLM deployment: simpler to implement, more stable to train, and models are easier to audit — which matters for regulatory compliance (Rafailov et al., 2023)
Interpretation
DPO increases the log-probability of the preferred response \(y_w\) relative to \(\pi_{\mathrm{ref}}\) while decreasing that of \(y_l\) — a direct implementation of the preference signal.
Adapting to finance: two stages

Domain adaptation: continued pre-training, then task fine-tuning

Domain adaptation is not one step. A financial LLM typically requires a large unsupervised stage to shift representations, followed by a small supervised stage for the specific task.

Stage 1 — DAPT (domain-adaptive pre-training)
Train on a large financial corpus (CLM or MLM), learning rate \(10^{-5}\)–\(10^{-4}\), cosine schedule with warmup. Mix in 1–5% general text (replay buffer) to prevent catastrophic forgetting.
Stage 2 — Task-specific fine-tuning
Train on 1,000–100,000 labelled examples. Very small learning rate (\(10^{-5}\) with LoRA; \(5 \times 10^{-6}\) with full fine-tuning). Example: LLaMA-2 (7B) on Financial PhraseBank — two-stage achieves ≈ 94% vs ≈ 89% (Stage 2 alone) vs ≈ 79% (zero-shot).
lesson from BloombergGPT The finance-specific corpus was exhausted at ≈ 363B tokens — less than the Chinchilla-optimal ≈ 1T for 50B parameters. Domain-specific pre-training faces an inherent data ceiling.
A calibration warning

More context is not always better: information overload

Even aligned models have a sweet spot. Feed them too much information and accuracy actually falls — a practical constraint on RAG and prompt engineering design.

Balogh & Didisheim (2025) RLHF-aligned models in financial analysis tasks show an inverted-U relationship: accuracy first rises then falls as the volume of input context exceeds the model's effective capacity. Relevant for designing RAG pipelines and prompt length in financial applications.
  • Implication: retrieval pipelines should return the most relevant passages, not the most passages.
  • Practical mitigations: prompt length caps, ranking-based retrieval (MMR, cross-encoder reranking).
04

Finance models and evaluation

The flagship finance models — and the metrics that decide whether they work.
Domain adaptation that paid off

FinBERT: same architecture, finance diet, +7.8 points

Take BERT, keep reading it financial text, and sentiment accuracy jumps — almost entirely from what it read, not from any new architecture.

How it was built (Yang et al., 2020)
BERT-base (110M params) continued pre-training on: TRC2 Reuters (1.8 GB), Financial PhraseBank (Malo et al., 2014), and analyst reports. MLM objective; WordPiece vocabulary unchanged — gains arise from weight updates, not vocabulary expansion. Huang et al. (2023): larger variant on 4.9B tokens predicts stock returns and corporate fraud.
ModelAccuracy
Human upper bound (inter-annotator agreement, Malo et al. 2014)≈ 97%
FinBERT88.5%
BERT-large (general)80.7%
Dictionary / rule-based≈ 72%

Financial PhraseBank, all-agree split. The 7.8 pp gain over BERT-large comes almost entirely from domain-specific continued pre-training, not architectural changes. Typical FinBERT gains over general BERT are 5–15 pp on in-domain data.

Beyond FinBERT

A family of finance encoder models

FinBERT proved the concept. A generation of variants extended it to richer architectures, larger corpora, and non-English markets — all following the same principle.

RoBERTa-financial
Replaces BERT's next-sentence-prediction objective with longer training and larger batches; stronger representations for classification and extraction tasks.
FLANG (2022)
Financial Language model for NLP in finance — covers five financial domains. Trains on a substantially larger financial corpus than FinBERT.
the general principle Domain-adaptive pre-training of encoder models consistently improves financial NLP by 5–15 percentage points on in-domain data. The gains arise from richer representations of financial terminology, not architectural changes.
Non-English markets
Models pre-trained on German or French regulatory text show similar gains relative to multilingual BERT. Architecture stays identical; the corpus changes.
A finance giant — built against the rule

BloombergGPT: 50B parameters, but under-trained

Bloomberg built a 50-billion-parameter finance model on its proprietary data. By the Chinchilla ruler it was fed too little — proof that even deep pockets miss the optimum.

Training corpus (Wu et al., 2023)
708B total tokens: 363B finance-specific (Bloomberg News 105B, Web 88B, Filings 88B, Press 63B, Social 19B) + 345B general (The Pile). Mix: 51% finance / 49% general. ALiBi positional encodings.
BloombergGPTChinchilla optimal
Parameters50B50B
Training tokens363B≈ 1T (50B × 20)

Under-trained by the Chinchilla criterion. Finance corpus was exhausted; adding more general text would dilute financial content below 50%.

results BloombergGPT outperforms GPT-NeoX-20B by 10–20% on financial benchmarks (FPB, FiQA-SA, Headline, NER, ConvFinQA) while matching general NLP performance (MMLU, BIG-bench).
What finance LLMs actually do

Three task families: NER, numerical QA, and summarisation

Financial NLP is not just sentiment. Named entity recognition, numerical reasoning over tables, and faithful summarisation each require different architectures and training strategies.

Named Entity Recognition
Token-level classification head on an encoder: B-ORG, I-ORG, B-MON, etc. (CoNLL-2003 BIO scheme extended to financial entities: company names, instruments, monetary amounts).
Numerical QA (FinQA)
Chen et al. (2021): 8,281 QA pairs requiring multi-step arithmetic over earnings reports. Program-executor architecture — model generates symbolic operations evaluated by an external calculator. Human accuracy ≈ 91%; top neural systems ≈ 68–75% at publication.
Summarisation and factual fidelity
CLM or span-corruption objective on (document, summary) pairs achieves reasonable ROUGE scores, but financial summaries require factual precision — "revenue grew 2%" vs. "12%" is catastrophic. RAG is one practical mitigation.
Multi-task (Zhang et al., 2023)
LoRA fine-tuning of Llama 2 for simultaneous sentiment, key-point extraction, summarisation, and NER — competitive accuracy at a fraction of full fine-tuning cost. Confirms PEFT methods are viable for end-to-end financial NLP pipelines.
The score sheet

Financial NLP benchmarks: what they measure and how hard they are

Practitioners need a shared score sheet. Five benchmarks define the landscape, each testing a different capability — from simple sentiment to multi-hop arithmetic.

BenchmarkTask typeSizePrimary metric
FPB (Financial PhraseBank)3-class sentiment4,846Accuracy
FiQA-SAAspect sentiment (implicit jargon)1,173MAE
FinQANumerical QA (multi-step)8,281Exec. accuracy
ConvFinQAConversational QA3,892Exec. accuracy
Headlines (Sinha et al.)9-class labelling11,412Avg. F1
FinBen (Xie et al., 2024)
42 datasets, 24 tasks, 21 models (GPT-4, ChatGPT, Gemini, open-source). Verdict: LLMs excel at extraction and textual analysis but struggle on advanced numerical forecasting and decision-making — exactly what practitioners want most.
How do we grade a model?

Perplexity and Macro-F1: fluency vs. fairness

Two different questions: how surprised is the model by real text (perplexity), and how well does it classify every category — including the rare, important ones (Macro-F1)?

Perplexity
Measures how surprised the model is by held-out text — lower is better. Three limits: (1) not comparable across vocabulary sizes; (2) not a task metric; (3) in-domain perplexity does not predict zero-shot performance on out-of-domain tasks. Best used as a training diagnostic.
Macro-F1
Treats all classes equally regardless of frequency — right for imbalanced financial datasets where rare event classes (fraud alerts, covenant violations) matter as much as common ones.
Summaries and evaluation limits

ROUGE for summaries — and its limits in finance

ROUGE checks how much of a reference summary the model recovered — but in finance, surface overlap does not guarantee factual accuracy.

the factuality gap ROUGE rewards n-gram overlap with a reference; it does not penalise hallucinated numbers. A summary reporting "revenue grew 2%" scores the same as "revenue grew 12%" if all other n-grams match. Production pipelines supplement ROUGE with NLI-based factuality checks: a secondary model verifies that every claim in the summary is entailed by the source document.
Breaking the model on purpose

Four ways a finance LLM fails under red-teaming

Adversarial testing surfaces recurring, finance-specific failure modes — the kind that turn a confident answer into a compliance incident.

  1. Factual hallucination — fabricated prices, earnings figures, or specific revenue numbers; "revenue grew 2%" when the 10-K says 12%.
  2. Regulatory hallucination — non-existent regulatory provisions, wrong article numbers, statements attributed to bodies that did not make them.
  3. Compliance failure — personalised investment advice without required licensing disclosures; text designed to manipulate market sentiment.
  4. Information barrier violations — inferring material non-public information from patterns in training data.
empirical illustration · Lopez-Lira & Tang (2023) ChatGPT sentiment scores predicted next-day stock returns; long-short strategy Sharpe ratios were high in early sample and declined as the signal became publicly known and arbitraged away. Any published alpha source degrades once it is public.
05

Safety and governance

The biases baked into the data, the lies the model tells, and the rulebook around both.
The data has a worldview

Four biases baked into financial training data

A model inherits the blind spots of what it read. In finance, four recurring biases systematically tilt its picture of the world — these are not edge cases but structural features of every financial corpus (Bender et al., 2021).

survivorship bias Corpora overrepresent successful firms: public companies file EDGAR; bankrupt or never-public firms do not. The model learns a rosier world than practitioners inhabit.
Temporal bias
"CDO" meant one thing in 2006 (sophisticated product) and another in 2009 (toxic instrument). Models trained on multi-decade corpora conflate these meanings without explicit temporal context.
Geographic & cultural bias
English-language, US-centric text dominates: US SIC codes vs. NACE codes, GAAP vs. IFRS, SEC vs. European regulatory standards. Non-US deployment requires explicit awareness.
Analyst consensus bias
Commentary echoes dominant sell-side views; contrarian signals are rarer in the training distribution. Models learn to replicate consensus rather than independent analysis.
When the model makes things up

Two kinds of hallucination, four layered defenses

Models invent facts and misquote rules. No single fix works — production systems stack several defenses with an audit trail at every step (Ji et al., 2023).

Two hallucination types
  • Factual — fabricated prices, dates, figures not in any training document
  • Regulatory — rules that are outdated, misquoted, or jurisdiction-mismatched
  1. RAG — ground outputs in retrieved, verified passages (EDGAR filings, verified news articles)
  2. Confidence calibration — flag or reject responses below a calibrated threshold
  3. Output verification — a checker flags claims inconsistent with a structured knowledge base
  4. Human-in-the-loop — route low-confidence / high-stakes outputs to expert review
no single mitigation is sufficient Production deployments should layer at least two mitigations, with audit trails at every step.
The rulebook

Three regimes that govern finance AI

Deploying an LLM in finance means answering to regulators. Three frameworks set the bar for explainability, validation, and oversight — and they are not optional.

MiFID II (Art. 37)
Research independence: LLM contributions need demonstrable suitability and explainability. Attention-weight visualisations are not sufficient — they show co-occurrence, not causal reasoning. Firms must implement auxiliary explanation mechanisms (LIME, SHAP, structured decision logs).
SR 11-7 (Fed)
Model-risk management with tiered validation. High-risk models (credit, capital, trading) need independent validation, assumption documentation, and periodic monitoring. Industry practice: lighter validation for summarisation; full SR 11-7 for credit scoring.
EU AI Act (Aug 2026)
High-risk systems (credit scoring, insurance pricing): technical documentation, human oversight, accuracy and robustness requirements before deployment. GPAI models with systemic risk: adversarial testing + incident reporting to the European AI Office.
Operationalizing the rules

Classify the risk, then control it

Governance starts by labelling each use case by how much damage a bad output could do — then attaching controls proportional to that risk.

TierExamplesControls required
LowInternal Q&A, document searchStandard access controls, logging
MediumEarnings summarisation, first-pass compliance screeningAudit trails, human review sample
HighCredit decisioning, trade recommendation, regulatory filingFull SR 11-7 validation, EU AI Act registration
Four-component governance framework
1. Risk classification (Low/Medium/High by autonomy and impact) · 2. Audit trails (prompts, model version, parameters, outputs, timestamps — immutable; Tier 3: retain ≥7 years under SEC Rule 17a-4) · 3. Monitoring (distributional shift, accuracy degradation, safety violations) · 4. Incident response (documented mitigation; MiFID II: disclose to national competent authority).
Wrap-up

What we covered — and where Lecture 4 goes

Today

  • Data — 0.5% finance on the web; EDGAR, transcripts, Bloomberg; quality pipelines (RefinedWeb), MinHash dedup, curriculum mixing, replay buffers
  • Scaling — Chinchilla \(D^*/N^* \approx 20\); GPT-3 over-parameterised, BloombergGPT under-trained; BPE + SentencePiece tokenizers
  • Fine-tuning — LoRA (0.12%, 90 min vs. 40 hr), instruction tuning (FLAN, InvestLM, PIXIU/FinMA 136K), domain adaptation (two-stage DAPT)
  • Alignment — RLHF (SFT → reward → PPO); DPO simplifies to one supervised objective; information-overload warning (Balogh & Didisheim, 2025)
  • Finance — FinBERT +7.8 pp; BloombergGPT 10–20% gain; FinQA program executor (human 91%); FinBen (42 datasets, LLMs struggle on forecasting)
  • Governance — MiFID II + SR 11-7 + EU AI Act 2026; attention weights are not explanations; four-component governance framework
Lecture 4 — AI Agents in Finance
How do we compose trained LLMs into agents that plan, use tools, retrieve data, and operate autonomously? Multi-agent orchestration, tool-use APIs, and agent-specific failure modes.

Key refs: Hoffmann et al. (2022) · Wu et al. (2023) · Rafailov et al. (2023) · Lopez-Lira & Tang (2023) · Balogh & Didisheim (2025).

A

Appendix — systems & efficiency

Distributed training, kernels, and PEFT variants. Beyond the core lecture.
Appendix · scaling the hardware

Three ways to split a model across machines

A 7B model in full precision needs ≈ 112 GB — more than any single GPU holds. Three complementary strategies address this; they are combined in practice.

TypeWhat is partitionedKey mechanism
Data parallelismBatch (each device holds full model)Ring-AllReduce gradient aggregation
Tensor / model parallelismWeight matrices column-wise (Megatron-LM)All-gather / all-reduce intra-layer
Pipeline parallelismLayer groups to successive devicesMicro-batches; bubble fraction
Appendix · doing more with less memory

Lower precision, recomputed activations, fewer wasted moves

Three engineering tricks shrink the memory bill so far bigger models fit on the same chips.

Mixed precision (bfloat16)
Weights in 16-bit with an fp32 master copy for the optimiser; halves memory and HBM bandwidth. bfloat16 preferred: same 8-bit exponent as float32 preserves dynamic range needed for small gradients. Dynamic loss scaling prevents gradient underflow.
Gradient checkpointing
Discard intermediate activations and recompute them in the backward pass. Activation memory falls from \(O(L \cdot T \cdot d)\) to \(O(\sqrt{L} \cdot T \cdot d)\) with optimal checkpoint placement, at ≈ 33% extra FLOPs.
Appendix · the attention kernel

FlashAttention: exact attention, far less memory traffic

Attention's bottleneck is shuffling a huge matrix to and from memory. FlashAttention keeps the work in fast on-chip memory — same answer, far fewer round-trips.

Why it matters
For \(T = 4{,}096\), the naive attention matrix is ≈ 32 MB per head, accumulating across heads and layers. FlashAttention tiles into SRAM, reducing HBM traffic from \(O(T^2)\) to subquadratic. Combined: bfloat16 + checkpointing + FlashAttention enable training models 4–8× larger on the same hardware. FlashAttention enables sequence lengths of 32,000–100,000 tokens that would otherwise be memory-prohibitive.
Appendix · other PEFT methods

Prefix tuning and adapters — and why LoRA usually wins

LoRA is not the only cheap-adaptation method. Two alternatives steer the model without retraining it — but each carries a catch LoRA avoids.

Prefix tuning (Li & Liang, 2021)
Learnable prefix matrices \(P_K, P_V \in \mathbb{R}^{L_p \times d_h}\) prepended to K and V at every layer; only the prefixes train. Effective for generation; steals context-window budget.
Adapters (Houlsby et al., 2019)
A small bottleneck module (project down, non-linearity, project back) inserted after each sub-layer, with a residual connection so the adapter is an identity at initialisation. Adds \(4rdL\) parameters; adds inference latency unless fused.
why LoRA wins in practice Zero inference overhead after merging \(W_0 \leftarrow W_0 + \tfrac{\alpha}{r}BA\); compatible with quantised weights (QLoRA: 4-bit base model + LoRA adapters in float16); multiple adapters swappable per task without reloading the base model; simpler implementation via the PEFT library.