Model Risk: Establishing a model governance system for a tier 1 G-SIB bank

Challenge and Regulatory Context

  • Our client’s external auditors had identified the absence of an overarching model governance framework.
  • The goal was to help the client set up a model governance system to monitor the model life cycle.
  • Model risk had become an important regulatory topic with the publication of the OCC’s SR 11-7.
  • Monitoring and mitigating model risk were therefore central to the new function.


  • We provided an initial set of model control reviews for various model types.
  • We were able to leverage much of the work done by model developers and validators in order to avoid repeat testing.
  • Our model governance tool proved both suitable for, and adaptable to, a broad range of model types. It was subsequently employed at several tier 1 banks.


  • We developed a new methodology to break model risk into three separate types: statistical risk, assumption risk and procedural risk.
  • We further developed our “model map” concept to decompose a model into its individual input, process and reporting elements and trace the connections between them.
  • We created a model risk management tool which works alongside the model map. This tool is comprehensive in that it compares the controls around each model element with a self-consistent master list.
  • The tool then generates a semi-automated “control review” document to highlight high risk areas of the model, as well as any gaps in the control regime throughout the model lifecycle.

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