Banks are revisiting model risk management as the federal banking agencies reset their supervisory posture on model risk for the first time since 2011, replacing most of SR 11-7 with a materiality-based approach to model governance.
In our CRA Insight, we examine the revised interagency guidance, issued by the Federal Reserve as SR 26-2 (OCC Bulletin 2026-13; FDIC FIL-15-2026). We also discuss the planned interagency request for information on generative and agentic AI and the increasingly divergent international approaches to model and AI risk governance.
The practical question for banks goes beyond updating policies and inventories. Institutions that build defensible model tiering, exposure quantification, and credible vendor oversight now will be positioned to deploy models, including AI and machine learning applications, faster and more safely than peers that treat model risk as a compliance exercise.
Our CRA Insight outlines the key changes and practical steps banks can take now here.
