Model Risk Management Policy Template (SR 26-2, PRA SS1/23)
Model definition, roles, inventory fields, tiering matrix, development, risk-based validation, monitoring, overlays, vendor models, GenAI scope, issues, reporting
Як використовувати: Use it when a bank sets or rewrites its model risk policy after SR 26-2 replaced SR 11-7 on 2026-04-17. Fill the model definition and the tiering method first, because every later requirement scales with the tier. The main pitfall is copying fixed annual validation cycles or leaving generative AI ungoverned because it is outside SR 26-2.
Перегляд
Model Risk Management Policy: [Institution name]
Board-approved policy that defines what a model is, who is accountable for model risk, how models are inventoried and tiered, and the standards for development, validation, ongoing monitoring, use, third-party models, limitations and overlays, issue management and reporting. It follows the US interagency Revised Guidance on Model Risk Management of 2026-04-17 (Federal Reserve SR 26-2, OCC Bulletin 2026-13, FDIC FIL-15-2026), which superseded SR 11-7 (2011) and SR 21-8 (2021); the PRA Supervisory Statement SS1/23 (Model risk management principles for banks, effective 2024-05-17, five principles cited by number and name); and the ECB guide to internal models (revised version of 28 July 2025, reflecting CRR3 and adding machine-learning expectations) for institutions using internal models for own funds. Replace every
[bracketed]value and every row marked Example. The worked example uses the fictional Fernhollow Bank, a mid-sized EU credit institution with a US branch. This is a document format, not legal, regulatory or risk advice. Obtain the guidance or regulation for the normative text.
Document control
| Field | Value |
|---|---|
| Document ID | [MRM-POL-001] |
| Institution and scope | [Legal entity, LEI, consolidated group, branches] |
| Version | [1.0] |
| Status | [Draft / In review / Board approved / Superseded] |
| Owner | [@chief-risk-officer] |
| Policy administrator | [@head-of-model-risk-management] |
| Approvers/reviewers | [@board-risk-committee-chair], [@chief-financial-officer], [@head-of-internal-audit], [@head-of-compliance] |
| Approving body and minute reference | [Board risk committee, minute BRC-YYYY-NN] |
| Effective date | YYYY-MM-DD |
| Next scheduled review | YYYY-MM-DD (at least annually) |
| Last updated | YYYY-MM-DD |
| Classification | [Internal] |
| Supervisory frameworks considered | [SR 26-2 / PRA SS1/23 / ECB guide to internal models / national] (SS1/23 applies to UK-authorised firms; keep it only if the group has a UK entity) |
Approvals
| Role | Name | Decision | Date |
|---|---|---|---|
| Head of model risk management (drafts) | [@name] | [Submit] | YYYY-MM-DD |
| Chief risk officer (recommends) | [@name] | [Recommend] | YYYY-MM-DD |
| Board risk committee (approves) | [@name] | [Approve / Approve with conditions] | YYYY-MM-DD |
Revision history
| Version | Date | Author | Change |
|---|---|---|---|
| 0.1 | YYYY-MM-DD | [@author] | First draft |
| 1.0 | YYYY-MM-DD | [@author] | Approved by the board risk committee |
| [2.0] | 2026-10-25 | [@author] | [Example: replaced SR 11-7 references with SR 26-2, OCC Bulletin 2026-13 and FDIC FIL-15-2026; removed fixed annual validation cycle; added GenAI exclusion and AI policy link; updated to the July 2025 revision of the ECB guide to internal models] |
Contents
- 1. Purpose and principles
- 2. Scope and model definition
- 3. Roles and responsibilities
- 4. Model inventory
- 5. Model risk tiering
- 6. Development and documentation standards
- 7. Independent validation
- 8. Ongoing monitoring and outcomes analysis
- 9. Model use, limitations and overlays
- 10. Vendor and other third-party models
- 11. AI, machine learning and generative AI
- 12. Model changes and decommissioning
- 13. Issue management
- 14. Reporting, risk appetite and policy exceptions
- 15. Regulatory mapping
- 16. Glossary and references
- Standard and licence note
1. Purpose and principles
This policy sets out how [Institution name] identifies, measures, controls and reports model risk: the risk of adverse consequences from decisions based on model outputs that are wrong or misused. It applies across the model lifecycle, from the first idea for a model to its retirement.
The bank commits to the following principles:
- Proportionality. The effort spent on a model matches its materiality and inherent risk. Low-tier models receive lighter treatment so that resources concentrate where errors would hurt.
- Effective challenge. Every material model is challenged by people with the expertise, independence and standing to require change.
- Transparency of limitations. Every model has documented limitations, and users know them before they rely on the output.
- Single source of truth. All models in scope are in one inventory that drives validation planning, monitoring and reporting.
- Accountability. Each model has a named owner who is accountable for its performance and appropriate use.
- Aggregate view. Model risk is assessed for individual models and in aggregate, including shared data, shared assumptions and chains of models feeding each other.
The policy supports the bank's risk appetite for model risk in the Risk Appetite
Statement (finance/risk-appetite-statement) and the internal capital assessment in the
ICAAP Report (finance/icaap-report).
2. Scope and model definition
2.1 Entities and activities in scope
This policy applies to [all entities of the group, including branches and subsidiaries]. Local requirements that are stricter apply in addition.
Example: Fernhollow Bank, a significant institution supervised directly by the ECB, applies the policy to the head office in the EU, its two EU subsidiaries (leasing and payments) and its New York branch. For the US branch the bank also considers SR 26-2 where its US supervisor expects it, noting that the guidance is expected to be most relevant to banking organisations above USD 30 billion in total assets and may be relevant below that threshold when model use is significant.
2.2 Definition of a model
For this policy, a model is a quantitative method, system or approach that applies statistical, economic, financial or mathematical theory and assumptions to transform input data into quantitative estimates used for decisions, reporting or risk management. A model has three parts: inputs, a processing component that applies the theory, and an output used by the business.
The following are not models under this policy but are governed as end-user computing tools or IT applications: simple arithmetic calculations, deterministic rule-based processes and software that does not rest on statistical, economic or financial theory. This is deliberately wider than the SR 26-2 definition, which refers to complex quantitative methods based on statistical, economic or financial theory; the bank also captures simpler and mathematical methods so that tiering, not the definition, decides how much governance applies. The exclusions follow SR 26-2. When a rule-based process uses thresholds that were set by statistical analysis (for example, transaction monitoring thresholds tuned on historical alert outcomes), the tuning analysis is in scope as a model even if the runtime rules are not.
2.3 Model identification
Business units must notify model risk management of any new method that may meet the definition before it is used for decisions. Model risk management decides whether it is a model and records the decision. Disputed decisions go to the model risk committee.
| Candidate | Decision | Reason |
|---|---|---|
| Retail mortgage PD scorecard (Example) | Model | Statistical estimate used for capital and pricing |
| Fee calculation in core banking (Example) | Not a model | Deterministic arithmetic |
| Transaction monitoring scenario rules (Example) | Not a model at runtime; threshold tuning study is a model | Thresholds derived statistically |
| Customer service GenAI assistant (Example) | Outside this policy; governed by the AI policy | Generative AI is outside SR 26-2 scope (see section 11) |
3. Roles and responsibilities
| Role | Responsibilities |
|---|---|
| Board and board risk committee | Approve this policy and the model risk appetite; receive model risk reporting at least [quarterly]; ensure enough resources and expertise for model risk management |
| Senior management and model risk committee | Implement the policy; approve Tier 1 models for use; decide on use of models with open high-severity findings; approve exceptions within delegated limits |
| Model owner (first line) | Accountable for the model's purpose, performance and appropriate use; keeps the inventory entry current; funds remediation |
| Model developer (first line) | Builds the model to the standards in section 6; documents data, method, assumptions, limitations and testing |
| Model user (first line) | Uses the model within approved purpose and limitations; reports unexpected outputs; applies approved overlays only |
| Model risk management (second line) | Owns this policy and the inventory; sets tiering; plans and performs or oversees validation; reports aggregate model risk |
| Validators (second line, internal or external) | Independent review of conceptual soundness, data, implementation and outcomes; issue findings and a validation rating |
| Internal audit (third line) | Assesses whether model risk management is rigorous and effective and whether the policy is applied; does not duplicate validation |
| Data owners | Ensure input data quality and lineage for models that use their data |
| Compliance and legal | Advise on fair lending, consumer protection, AI and data protection requirements affecting models |
Independence of validation means that validators do not report to the model owner or developer, are not paid on the results of the models they review, and have authority to escalate findings to the model risk committee. SR 26-2 places the emphasis on the rigour and effectiveness of the review rather than on organisational structure, so a small bank may use qualified staff from another unit or an external firm, provided that model risk management oversees and integrates their work.
4. Model inventory
Model risk management maintains one inventory covering models in development, in use, and retired within the last [five] years. Model owners must update their entries within [10] business days of any change. The inventory supports the individual and aggregate view of model risk and must hold enough information to understand each model's risks.
4.1 Mandatory fields
| Field | Description | Maintained by |
|---|---|---|
| Model ID | Unique ID, format MOD-NNN | Model risk management |
| Name and version | Name and current version | Model owner |
| Purpose and uses | Approved uses, including regulatory uses | Model owner |
| Model type and method | For example logistic regression, simulation, gradient boosting | Developer |
| Owner, developer, primary users | Named roles and units | Model owner |
| Tier | Tier from section 5, with scoring | Model risk management |
| Status | In development / Approved / Approved with conditions / In use under exception / Retired | Model risk management |
| Upstream and downstream dependencies | Models and data feeding it, models it feeds | Developer |
| Data sources | Systems and datasets | Developer |
| Vendor | Name and product, if third-party | Model owner |
| Last validation date and rating | Date and outcome | Model risk management |
| Next validation due | Date from the risk-based plan | Model risk management |
| Open findings | Count by severity, with IDs | Model risk management |
| Limitations and overlays | Short list with references | Model owner |
| Regulatory permission | Supervisory approval reference for internal models | Model owner |
4.2 Inventory extract
| Model ID | Name | Use | Owner | Tier | Last validation | Rating | Next due |
|---|---|---|---|---|---|---|---|
| MOD-001 (Example) | Retail mortgage PD v3.0 | IRB own funds, pricing | Head of retail credit risk | 1 | 2026-03-31 | Satisfactory with findings | 2027-03-31 |
| MOD-002 (Example) | IFRS 9 ECL macroeconomic module | Impairment | Head of credit risk modelling | 1 | 2025-11-30 | Satisfactory | 2027-11-30 |
| MOD-003 (Example) | Historical simulation VaR | Market risk limits | Head of market risk | 2 | 2025-06-30 | Satisfactory | 2027-06-30 |
| MOD-004 (Example) | Non-maturity deposit behavioural model | IRRBB | Head of ALM | 2 | 2025-09-30 | Needs improvement | 2026-12-31 |
| MOD-005 (Example) | Card fraud score (vendor) | Fraud detection | Head of fraud operations | 2 | 2026-01-31 | Satisfactory | 2027-07-31 |
| MOD-006 (Example) | TM threshold tuning study | AML alert thresholds | MLRO | 3 | 2026-05-31 | Satisfactory | 2028-05-31 |
5. Model risk tiering
Tier each model by combining two assessments. SR 26-2 describes materiality as the product of exposure (the size of the decisions or portfolios that depend on the output) and purpose (for example, regulatory and financial risk uses weigh more), and inherent risk as driven by assumptions, complexity, input quality and data constraints. PRA SS1/23 Principle 1 also expects a model risk classification. The bank's method is as follows.
5.1 Materiality score
| Factor | Low (1) | Medium (2) | High (3) |
|---|---|---|---|
| Exposure | Portfolio or decision value below [EUR 100 million] | [EUR 100 million to 1 billion] | Above [EUR 1 billion] |
| Purpose | Internal analysis, no direct decision | Business decision, pricing, limits | Regulatory capital, financial reporting, regulatory submission |
| Customer impact | None | Indirect | Direct decisions about individual customers |
Materiality is the highest of the three factor scores.
5.2 Inherent risk score
| Factor | Low (1) | Medium (2) | High (3) |
|---|---|---|---|
| Complexity | Transparent, few variables | Moderate | Highly non-linear, opaque, or many interacting components |
| Assumptions | Few and well supported | Several, partly judgemental | Many or highly judgemental |
| Data | Long, clean, relevant history | Gaps or proxies | Short, low-default or unrepresentative history |
| Interconnection | Stand-alone | Feeds one other model | Feeds several material models |
Inherent risk is the rounded average of the four factor scores.
5.3 Tier matrix
| Materiality \ Inherent risk | Low (1) | Medium (2) | High (3) |
|---|---|---|---|
| High (3) | Tier 2 | Tier 1 | Tier 1 |
| Medium (2) | Tier 3 | Tier 2 | Tier 1 |
| Low (1) | Tier 3 | Tier 3 | Tier 2 |
Example: MOD-001 has materiality 3 (regulatory capital) and inherent risk scores of 2 (complexity), 2 (assumptions), 2 (data) and 3 (feeds ECL, pricing and stress testing). The average is 2.25, rounded to 2, so the model sits at materiality High and inherent risk Medium, which is Tier 1.
Model risk management may raise a tier by judgement and must record the reason. Lowering a tier below the matrix result requires model risk committee approval.
6. Development and documentation standards
Development starts with a clear statement of purpose and intended use, agreed with the
model owner and key users. SR 26-2 treats this as the basis for choosing data, methods
and tests. Developers then document the work in the Model Development Document
(finance/model-development-document), which must cover, at a depth proportionate to
the tier:
- purpose, scope, users and intended uses, with uses that are not permitted;
- theory and design choices, including alternatives considered and why they were rejected;
- data sources, definitions, quality checks, exclusions and their effect;
- methodology, estimation and calibration;
- key assumptions and expert judgements, each with support;
- developmental testing: performance, stability, sensitivity, out-of-sample and out-of-time testing, and benchmarking;
- limitations and their mitigants;
- implementation and user acceptance testing;
- the ongoing monitoring plan with metrics and thresholds.
| Requirement | Tier 1 | Tier 2 | Tier 3 |
|---|---|---|---|
| Full development document | Required | Required | Short form allowed |
| Benchmark or challenger model | Required | Recommended | Not required |
| Sensitivity analysis of key assumptions | Required | Required | Recommended |
| User involvement and sign-off of purpose | Required | Required | Required |
| Model card summary | Required | Required | Recommended |
| Code under version control with peer review | Required | Required | Required |
Use the Model Card (ai-data/model-card) as the short summary that travels with the
model to users and committees.
7. Independent validation
7.1 Scope of validation
Validation assesses whether a model performs as intended and identifies its limitations. It covers, in proportion to tier:
- conceptual soundness: design, theory, assumptions, judgements, data selection and developmental evidence;
- data: relevance, quality, representativeness and lineage;
- implementation: whether the production code and process match the documented design, including input feeds and output use;
- outcomes analysis: comparison of outputs with realised outcomes, including back-testing, benchmarking and outlier analysis;
- the ongoing monitoring plan and its thresholds;
- use: whether actual use matches the approved purpose.
Validators record results in the Model Validation Report
(ai-data/model-validation-report). For market risk internal models, the back-testing
evidence is documented in the VaR Backtesting Report (finance/var-backtesting-report).
7.2 Timing and frequency
Validation normally takes place before first use. A model may be used before validation completes only for an urgent business need, with model risk committee approval, documented limitations, communicated restrictions and compensating controls such as usage limits or closer monitoring. The exception expires on a set date.
After first use, model risk management sets the next validation date for each model based on tier, the size and frequency of changes, monitoring results, data limitations and supervisory expectations.
| Tier | Full revalidation (bank rule) (Example) | Interim review (Example) | Trigger events that bring validation forward |
|---|---|---|---|
| Tier 1 | At least every [24] months | Annual review of monitoring results and open findings | Material change, monitoring breach, new use, regulatory request |
| Tier 2 | At least every [36] months | Review of monitoring every [12] months | As Tier 1 |
| Tier 3 | Every [48] months or on material change | Owner attestation every [12] months | Material change or monitoring breach |
The intervals above are the bank's own choice and must be justified in the validation plan. Supervisory requirements for internal models used for own funds (for example, CRR requirements for IRB validation and the ECB guide to internal models chapter on internal validation) may require annual validation activities for those models; where they do, they prevail.
7.3 Validation ratings and findings
| Rating | Meaning | Use consequence |
|---|---|---|
| Satisfactory | Fit for purpose, minor or no findings | Approved for use |
| Satisfactory with findings | Fit for purpose with findings to fix by set dates | Approved with conditions |
| Needs improvement | Material weaknesses; usable only with overlays or restrictions | Conditional use approved by the model risk committee |
| Unsatisfactory | Not fit for purpose | Use stopped or replaced; exception only by the committee for a set period |
Findings carry a severity (High, Medium, Low), an owner and a due date and are tracked under section 13.
8. Ongoing monitoring and outcomes analysis
Every model in use has an ongoing monitoring plan that defines metrics, thresholds,
frequency and the response to a breach. The plan is part of the development document and
is reviewed by validation. Use the Model Monitoring Plan
(ai-data/model-monitoring-plan) as the detailed format.
| Metric family | Typical metrics | Frequency (Tier 1) (Example) | Amber and red thresholds (Example) |
|---|---|---|---|
| Discrimination | Gini, AUC, KS | Quarterly | Gini drop of more than 5 points amber, 10 points red (model-specific thresholds in the development document prevail) |
| Calibration | Observed versus predicted default rate, binomial test | Quarterly | Red if the test rejects at the 99% level in two consecutive quarters |
| Stability | Population stability index (PSI) | Monthly | 0.10 amber, 0.25 red |
| Back-testing (market risk) | VaR exceptions | Daily, reported quarterly | As per the regulatory zone framework |
| Overrides | Override rate and direction | Monthly | [5%] to [10%] amber, above [10%] red (as for MOD-001) |
| Input data quality | Missing values, out-of-range values | Each run | As per data quality rules |
When a metric turns red, the model owner investigates within [20] business days and proposes a response: no action with justification, an overlay, recalibration, or redevelopment. Model risk management approves the response and may bring validation forward. SR 26-2 links deterioration directly to overlays, adjustment or redevelopment under the bank's policy, so the response must be documented, not implied.
9. Model use, limitations and overlays
9.1 Approved use
A model may be used only for the purposes recorded in the inventory. Extending a model to a new portfolio, product, geography or decision requires a use assessment by the owner, review by model risk management, and, for Tier 1 and Tier 2, validation of the new use before it starts.
9.2 Limitations
Each model's limitations are recorded in the development document, the model card and the inventory. Users must confirm that they have read the limitations before access is granted to Tier 1 model outputs.
9.3 Overlays and post-model adjustments
An overlay is any adjustment to model output outside the model's own logic. Every overlay must have:
- a reason linked to a known limitation or monitoring result;
- a quantified amount and a method that can be reproduced;
- an approver at the level set in the delegation table below;
- an expiry or review date, and a plan to remove it by fixing the model.
| Overlay size relative to model output (Example) | Approver |
|---|---|
| Below 5% | Model owner, notified to model risk management |
| 5% to 15% | Model risk committee |
| Above 15% or affecting regulatory capital | Model risk committee and chief risk officer, reported to the board risk committee |
Example: For MOD-004 (deposit behavioural model) monitoring showed faster outflows of non-maturity deposits after rate rises. The ALM team applied an overlay shortening the modelled duration of core deposits, approved by the model risk committee with an expiry on 2026-12-31, the date of the planned redevelopment.
10. Vendor and other third-party models
Vendor models, vendor data and parameters, and models built by consultants follow this policy in full. Before purchase, the model owner obtains from the vendor enough information to assess conceptual soundness, development data, performance and limitations, and secures contractual rights to documentation, change notices, and support for validation and audit. Where the vendor withholds code or data as proprietary, validation relies more on outcomes analysis, benchmarking and sensitivity testing on the bank's own data, and the validation report records the limitation.
Customisations made by the bank or for the bank are documented, justified and validated
as part of the model. Vendor releases are treated as model changes under section 12.
Vendor models that support critical or important functions are also recorded in the DORA
ICT Third-Party Register (compliance/dora-ict-third-party-register) and assessed under
the outsourcing and third-party risk policies.
11. AI, machine learning and generative AI
Machine learning models that produce quantitative estimates (for example, gradient boosting for fraud detection or neural networks for pricing) are models under this policy and follow every section, with these additional expectations for Tier 1 and Tier 2: explainability analysis suitable to the use, testing for bias and fair treatment where outputs affect individual customers, and monitoring for drift.
Generative AI and agentic AI models are outside the scope of SR 26-2. The guidance
states that institutions should still apply appropriate governance and controls to such
tools, and the agencies announced, in the 2026 issuance (FDIC FIL-15-2026), a forthcoming
request for information on AI models, including generative and agentic AI. The bank governs these systems under its AI
policy and the AI Risk Assessment (ai-data/ai-risk-assessment) and GenAI Risk Profile
(ai-data/genai-risk-profile) formats. When a GenAI system's output feeds a model in
scope (for example, text extracted by an LLM used as an input variable), the model owner
treats that output as a data source with its own quality controls.
For EU entities, also check obligations under Regulation (EU) 2024/1689 (AI Act). AI systems used to evaluate the creditworthiness of natural persons or establish their credit score are listed in Annex III as high-risk (check the exemption for fraud detection); check the consolidated text for the application date, which Article 113, as amended by Regulation (EU) 2026/1744, sets at 2 December 2027 for Annex III systems.
12. Model changes and decommissioning
| Change class | Examples | Required before production |
|---|---|---|
| Material | New method, new variables, new segment or use, recalibration of a Tier 1 model, vendor major release | Validation of the change; approval at the tier's approval level; for internal models used for own funds, check whether supervisory approval or notification is required |
| Non-material | Recalibration of a Tier 2 or 3 model within the approved method, code refactoring with identical outputs | Developer testing, model risk management review, inventory update |
| Administrative | Documentation corrections, owner change | Inventory update |
Model risk management reviews the cumulative effect of non-material changes at each interim review. A retired model stays in the inventory with its retirement date, its replacement, and confirmation that production feeds and user access have been removed.
13. Issue management
| Severity | Definition | Maximum remediation period (Example) | Escalation if overdue |
|---|---|---|---|
| High | Could lead to materially wrong decisions, reporting or capital | [6] months | Model risk committee and board risk committee |
| Medium | Weakness that could affect outputs under some conditions | [12] months | Model risk committee |
| Low | Improvement with limited impact | [18] months | Model owner and model risk management |
Closure requires evidence reviewed by the party that raised the finding or by model risk management. Extensions require approval one level above the normal closure approver.
| Finding ID | Model | Source | Severity | Owner | Due | Status |
|---|---|---|---|---|---|---|
| MRF-2026-011 (Example) | MOD-001 | Validation 2026-03 | Medium | Head of retail credit risk | 2027-01-31 | Open |
| MRF-2026-014 (Example) | MOD-004 | Monitoring breach | High | Head of ALM | 2026-12-31 | Overlay in place |
14. Reporting, risk appetite and policy exceptions
Model risk management reports to the model risk committee monthly and to the board risk committee at least [quarterly]. The report covers: the inventory by tier and status; validations completed and overdue; models in use under exception or with an Unsatisfactory or Needs improvement rating; open findings by severity and age; overlays in force and their total effect; monitoring breaches; and concentrations such as several Tier 1 models sharing one data source or one key assumption.
| Model risk appetite metric (Example) | Limit | Current |
|---|---|---|
| Tier 1 models in use without a current validation | 0 | 0 |
| High-severity findings overdue | 0 | 0 |
| Tier 1 models rated Needs improvement or worse | At most 1 | 0 |
| Overlays older than 12 months | At most 2 | 1 |
Exceptions to this policy require a written request with reason, duration, compensating controls and the owner's acceptance of the residual risk. The chief risk officer approves exceptions up to [six] months; longer exceptions go to the board risk committee. Model risk management keeps an exception log and reports it.
15. Regulatory mapping
| Framework | Element (by number or name) | Policy section |
|---|---|---|
| SR 26-2 / OCC Bulletin 2026-13 / FDIC FIL-15-2026 (2026-04-17) | Purpose and scope, model definition and exclusions | 2 |
| SR 26-2 | Overview of model risk (inherent risk, exposure, purpose, materiality, aggregate risk, effective challenge) | 1, 5 |
| SR 26-2 | Model development and model use | 6, 9 |
| SR 26-2 | Model validation (conceptual soundness, outcomes analysis) and ongoing monitoring | 7, 8 |
| SR 26-2 | Governance and controls (roles, internal audit, inventory, documentation) | 3, 4, 13, 14 |
| SR 26-2 | Vendor and other third-party products | 10 |
| PRA SS1/23 Principle 1 | Model identification and model risk classification | 2, 4, 5 |
| PRA SS1/23 Principle 2 | Governance | 3, 14 |
| PRA SS1/23 Principle 3 | Model development, implementation and use | 6, 9, 12 |
| PRA SS1/23 Principle 4 | Independent model validation | 7 |
| PRA SS1/23 Principle 5 | Model risk mitigants | 8, 9, 13 |
| ECB guide to internal models (revised 28 July 2025), overarching principles chapter | Internal governance, internal validation, internal audit, model use, machine learning, third-party involvement | 3, 7, 9, 10, 11 |
| CRR (Regulation (EU) No 575/2013 as amended), IRB requirements | Validation of internal estimates (Article 185) and default definition (Article 178) for IRB models | 7, and the development document |
The US agencies rescinded or superseded earlier documents when they issued the 2026 guidance: SR 11-7 and SR 21-8 (Federal Reserve), the Comptroller's Handbook booklet on model risk management and related OCC bulletins including 2021-19 on BSA/AML systems (OCC), and FIL-22-2017 and FIL-27-2021 (FDIC). Remove references to them from procedures and templates, and keep transaction monitoring systems within the general model risk framework described in this policy.
16. Glossary and references
| Term | Meaning in this policy |
|---|---|
| Model risk | Potential for adverse consequences from decisions based on incorrect or misused model outputs |
| Materiality | Importance of a model, from its exposure and purpose |
| Inherent risk | Likelihood that a model is wrong, from complexity, assumptions and data |
| Effective challenge | Critical analysis by objective, competent people with the standing to require change |
| Overlay | Adjustment to model output outside the model's own logic |
| Outcomes analysis | Comparison of model outputs with realised outcomes |
| Tier | Category from section 5 that sets the depth of oversight |
| Vendor model | Model, data or parameters supplied by a third party |
References:
- Board of Governors of the Federal Reserve System, FDIC and OCC, Revised Guidance on Model Risk Management, SR 26-2 with attachment "Supervisory Guidance on Model Risk Management", 2026-04-17; OCC Bulletin 2026-13; FDIC FIL-15-2026 (US federal works, public domain).
- Prudential Regulation Authority, SS1/23 Model risk management principles for banks, effective 2024-05-17 (cited by name and principle number only).
- European Central Bank, ECB guide to internal models, revised version published 28 July 2025 (replaces the February 2024 version; press release ssm.pr250728).
- Regulation (EU) No 575/2013 as amended by Regulation (EU) 2024/1623, Articles 178 and 185. EUR-Lex.
- European Banking Authority, Guidelines on PD estimation, LGD estimation and treatment of defaulted assets (EBA/GL/2017/16).
- Regulation (EU) 2024/1689 (AI Act), Annex III and Article 113, as amended by Regulation (EU) 2026/1744. EUR-Lex.
Standard and licence note
Based on public-domain US federal guidance (Federal Reserve SR 26-2, OCC Bulletin 2026-13 and FDIC FIL-15-2026) and EU public law (Regulation (EU) No 575/2013 as amended and Regulation (EU) 2024/1689, EUR-Lex, reuse with acknowledgement). Structure also aligned with the PRA Supervisory Statement SS1/23 and the ECB guide to internal models, which are cited by name, number and chapter only; no text from them is reproduced. The ECB guide is used with attribution to the European Central Bank. All text is original. Fernhollow Bank and every model, figure and finding are fictional. Check the current official version of each guidance and regulation before use. Template licence: MIT.
Схожі шаблони
Accounting Policy Manual Template (IFRS, US GAAP, IFRS 18)
Group accounting policies by area with IFRS and ASC references, thresholds, judgements register, elections register, IFRS 18 presentation, local GAAP bridges
Фінанси, інвестиції та облікCapital Structure and Dividend Policy Template (Board Paper)
Board policy on leverage and distributions: capital structure, WACC, target range, capital allocation, dividends, buybacks, reserves tests, stress tests
Фінанси, інвестиції та облікClient Risk Profile Template (MiFID II Suitability, Reg BI)
Fact-find and risk profiling: classification, finances, goals, knowledge, risk tolerance vs capacity for loss, sustainability preferences, model mapping