Financial services / Model governance / Evidence

Model risk support.Evidence that withstands review.

Model risk support connects a model’s purpose, assumptions, testing, validation, monitoring, and oversight to records that make continued reliance explainable. Use this page to scope a banking model-risk review, locate the evidence that matters, and preserve the reasoning behind a decision.

For model owners, validators, technology-risk professionals, AI governance teams, internal auditors, and business decision-makers working with quantitative models in financial services.

Current referenceSR 26-2 · April 17, 2026Supersedes SR 11-7 and SR 21-8 for Federal Reserve-supervised institutions. [1]
ApplicabilityRisk-based and proportionateExpected to be most relevant to institutions above $30 billion, with circumstances where it may inform smaller institutions. [2]
Scope boundaryGenAI and agentic AI excludedOutside this particular guidance; broader organizational risk governance remains relevant. [1]

What the term means

Model risk begins with decisions made from model outputs.

A model can be mathematically sound and still create business risk when its assumptions are violated, its data changes, or its outputs are used for a purpose it was never evaluated to support.

Under SR 26-2, model risk concerns potential adverse financial consequences associated with models, including decisions based on their outputs. Its magnitude reflects inherent risk—such as assumptions, complexity, and data constraints—in the context of model exposure and purpose. [1]

The practical question for assurance is not whether a model has many documents. It is whether reviewers can reconstruct what the model was meant to do, what was tested, who challenged it, how its performance is observed, and what would cause its use to be restricted or revised.

Read as guidance, not law

The interagency document presents non-prescriptive supervisory principles, not standalone enforceable standards. An institution still needs to assess its applicable laws, safety-and-soundness obligations, internal policies, and model exposure. [2]

Regulatory applicability / 2026

Classify the system before applying the evidence map.

The April 2026 revision limits the model definition for this guidance. Organizational size, model materiality, and type of technology influence how the principles should inform a review. Do not interpret an exclusion from SR 26-2 as exemption from all governance obligations. [1] [2]

Model context

Complex quantitative models

Statistical, economic, or financial theories underpin a method that processes inputs into quantitative estimates. Start with the institution’s model classification and materiality assessment.

Principles apply

Non-generative, non-agentic AI models

The revised guidance states that its principles apply here. Evaluate the model and its use rather than treating the label “AI” as either sufficient or disqualifying.

Outside this guidance

Generative AI and agentic AI

Expressly excluded from SR 26-2. Route these systems through appropriate AI, technology, security, third-party, and business-risk governance instead.

Excluded definition

Simple arithmetic and deterministic rules

Not covered by this model definition where statistical, economic, or financial theories do not underpin their design or use. Other controls may still be needed.

Applicability is not a hard $30 billion legal cutoff: the agencies say the guidance is expected to be most relevant above that size and may also be relevant to smaller organizations with significant model exposure. The FDIC likewise directs supervised institutions to tailor the review to their risk profile. [2] [5]

Model risk evidence crosswalk

Eight review areas. One reconstructable decision.

Read each row across: risk question → relevant records → assurance judgment. These are practical evidence prompts derived from the themes of SR 26-2—not prescribed documents, minimum tests, or a compliance score. [1]

  1. 01 / CLASSIFICATION

    Identity and use

    Why is this a model, and which business decisions actually rely on its output?

    Inventory entry; purpose and intended use; process map; ownership; model boundaries and connected dependencies.

  2. 02 / RISK PROFILE

    Inherent risk and materiality

    Which assumptions, data constraints, complexity, exposure, and purpose warrant deeper review?

    Assumptions; data-quality analysis; inherent-risk and exposure assessment; materiality rationale; aggregate dependencies.

  3. 03 / DEVELOPMENT

    Design and testing

    Do design choices and test conditions support the actual intended business use?

    Methodology and input documentation; development tests; out-of-time/out-of-sample work where appropriate; exceptions.

  4. 04 / VALIDATION

    Conceptual soundness

    Have qualified reviewers critically assessed reliability, assumptions, theoretical support, limitations, and results?

    Validation scope; reviewer challenge; comparative analysis; findings; responses; approval or limitation conditions.

  5. 05 / PERFORMANCE

    Outcomes and monitoring

    Do observed outcomes remain consistent with expectations, and what happens when results deteriorate?

    Outcome analysis; back-testing where useful; thresholds; monitoring history; deviations; adjustment or redevelopment decisions.

  6. 06 / GOVERNANCE

    Effective challenge

    Who has the expertise, objectivity, and organizational influence to challenge the model and change its use?

    Policies; responsibilities; independence considerations; challenge notes; escalation; accountable decision records.

  7. 07 / CONTINUITY

    Inventory and documentation

    Can another reviewer follow model versions, changes, issues, exceptions, and shared model dependencies?

    Model inventory; documentation register; changes; remediation history; dependencies; unresolved recommendations.

  8. 08 / EXTERNAL RELIANCE

    Vendor and customized models

    What does the bank know and test when code or data are proprietary, and how are local adjustments evaluated?

    Vendor evaluation; performance evidence; local validation and outcome analysis; customization rationale; monitoring and limitations.

Evidence file / Working structure

Build a model-risk evidence file from eight linked records.

These eight linked records connect the model, the underlying evidence, the challenge applied, and the decision. Adapt them to an existing model inventory, validation workflow, document repository, issue tracker, or GRC system.

01

Model profile

Identifier, classification, business owner, version, current use, users, approval boundary, dependencies, and inventory links.

02

Risk assessment

Inherent-risk factors, assumptions, exposure, purpose, materiality, data constraints, and justification for review depth.

03

Development record

Design choices, methodologies, input data, training or calibration periods, development testing, limitations, and accepted exceptions.

04

Validation record

Review scope, expertise, conceptual soundness, outcomes testing, independent challenge, findings, and management responses.

05

Monitoring record

Metrics, thresholds, frequency, data changes, outcome checks, alerts, overlays, performance trends, and follow-up actions.

06

Governance record

Decision authority, roles, review minutes, effective-challenge examples, conflicts, exceptions, and authorized use conditions.

07

Change and issue record

Version changes, use extensions, validation-impact decisions, findings, remediation, restrictions, waivers, and reassessment triggers.

08

Third-party record

Vendor claims and evidence, proprietary limitations, local tests, customizations, support arrangements, and retained gaps.

Minimum linkage to preserve

For each conclusion: model/use → claim or risk → evidence → reviewer challenge → decision/condition → owner → next review. This is the proposed traceability pattern, not a regulatory requirement.

Start small, scale by materiality

A lower-materiality model may use short records within existing systems. Higher-risk uses may require more extensive methodology documentation, validation work, monitoring, and governance evidence.

Monitoring / Review triggers

What should trigger a closer model review?

Useful monitoring connects a signal to a question and an accountable response. Choose measures based on the model, outcomes, data latency, and business consequence; do not apply one default threshold to every model. [1]

SignalExample checks / measuresWhat the reviewer needs to interpret
Input integrity
Null or missing-field rate, invalid values, feature schema changes, failed joins, data-feed or mapping changes.
Is the input trustworthy? Separate a pipeline defect from a changed population or a changed model.
Population shift
Input distributions versus a named baseline; drift tests or population stability measures where appropriate; shifts by segment or period.
Where and when did the distribution change? A shift test is a warning to investigate, not by itself proof of worse outcomes. [8]
Predictive performance
Error rates, discrimination measures, calibration, or back-testing against observed outcomes as appropriate for the model.
Are results still fit for the intended decision? Show the outcome window, denominator, evaluation population, and delayed-label limitations.
Concept drift
Changes in the relationship between model inputs and observed targets over time, tested where outcomes are available.
A changed input distribution and a changed input-to-outcome relationship are different phenomena; assess the right one. [7]
Use and exposure
New products, geographies, customer groups, approval thresholds, reliance volume, overrides, or a use outside original design.
Does the current use remain inside the evaluated boundary, and has business materiality changed? [1]
Model and vendor change
Version, parameter, training-data, vendor release, customization, implementation, or external-source changes.
Which earlier tests remain relevant? Identify necessary impact assessment, retesting, restrictions, and review ownership. [6]
After a signal breaches the agreed review rule

Record the metric and baseline, affected population and period, data quality checks, potential decision impact, review owner, evidence examined, approved disposition, next test and due date. Options may include additional investigation, a control overlay, limited use, recalibration, or redevelopment; the response depends on materiality and the evidence. [1]

The measures above are examples, not mandatory metrics or universal pass/fail cutoffs. The references distinguish supervisory model-risk principles from technical research on dataset shift and concept drift.

Worked review / Illustrative scenario

A model still runs. The evidence for relying on it has changed.

A bank uses a non-generative quantitative model to support lending decisions. A source-data change alters the distribution of incoming inputs. The model remains online, but its earlier tests may no longer describe current use. This scenario is illustrative, not a report of a specific bank.

  1. 01 / Signal

    Monitoring finds a deviation.

    Keep the dated alert, baseline definition, population affected, trend, threshold rationale, and recent data-pipeline changes. First determine whether the signal reflects a data issue, changed population, or model behavior.

  2. 02 / Challenge

    Revisit what earlier testing supports.

    Compare current inputs and observed outcomes with development and validation assumptions. Document where the original tests remain informative and where they no longer establish reliability.

  3. 03 / Decision

    Set a bounded response.

    The responsible owner considers additional testing, an overlay, temporary restriction, recalibration, or redevelopment as appropriate. Record who authorized the response and what information was considered.

  4. 04 / Closure

    Verify the corrective action.

    Preserve the updated evidence, challenge results, performance checks, residual limitations, authorization to continue or resume use, and the next reassessment trigger.

What good assurance preserves

The earlier approval is not automatically invalid, and a monitoring breach does not automatically mandate one response. Changes in input distribution alone should not be treated as proof of reduced model quality. The useful record explains what changed, whether reliance remains justified, who decided, and what conditions now apply. This reflects the guidance’s risk-based treatment of monitoring and model adjustments and research distinguishing shifts from their consequences. [1] [8]

Adjacent AI governance

Exclusion from SR 26-2 is not exclusion from oversight.

Generative and agentic AI systems fall outside this particular interagency model-risk guidance. Their risks may require different evidence: task evaluations, retrieval quality, data flows, tool permissions, human authorization, harmful-output safeguards, monitoring, incident records, and change controls.

For those uses, NIST’s voluntary AI Risk Management Framework and Generative AI Profile are useful additional references, alongside the institution’s legal, security, privacy, operational, and third-party risk obligations. Neither NIST document changes the scope of SR 26-2. [3] [4]

Sources & evidence notesInteragency guidance, primary AI references, and peer-reviewed monitoring research

The crosswalk, evidence-file structure, monitoring reference, and case scenario are infoSecured.ai practitioner syntheses. Regulatory sources inform model-risk scope and governance; research sources inform measurement and interpretation. Neither source type prescribes these exact records or a universal alert threshold.

  1. [1]
    Federal Reserve Board / FDIC / OCC (April 17, 2026). Supervisory Guidance on Model Risk Management.Full interagency text: overview of model risk, model development/use, validation, outcomes, monitoring, governance, and vendor models. Footnote 3 addresses GenAI and agentic exclusions.
  2. [2]
    Office of the Comptroller of the Currency (April 17, 2026). OCC Bulletin 2026-13: Model Risk Management—Revised Guidance.Official summary of the interagency revision, risk-based tailoring, expected institution-size relevance, rescissions, exclusions, and non-prescriptive status.
  3. [3]
    National Institute of Standards and Technology (2023). Artificial Intelligence Risk Management Framework (AI RMF 1.0).Voluntary cross-sector AI risk-management framework for GOVERN, MAP, MEASURE, and MANAGE functions.
  4. [4]
    National Institute of Standards and Technology (2024). NIST AI 600-1: Generative Artificial Intelligence Profile.Companion guidance for generative-AI-specific risks. Not an extension of SR 26-2’s scope.
  5. [5]
    Federal Deposit Insurance Corporation (April 17, 2026). FIL-15-2026: Agencies Revise the Interagency Model Risk Management Guidance.Explains applicability for FDIC-supervised institutions, relevance of significant model exposure, and the guidance’s risk-based, non-prescriptive approach.
  6. [6]
    Federal Reserve Board / FDIC / OCC (June 6, 2023). Interagency Guidance on Third-Party Relationships: Risk Management (SR 23-4).Useful adjacent source for vendor oversight, lifecycle monitoring, documentation rights, controls, contingency, and incident coordination. A replacement was proposed in September 2026; see [9] for status. Do not treat the proposal as final.
  7. [7]
    Gama, J., Žliobaitė, I., Bifet, A., Pechenizkiy, M., & Bouchachia, A. (2014). A Survey on Concept Drift Adaptation. ACM Computing Surveys, 46(4), Article 44.Peer-reviewed distinction between changed input-to-target relationships and approaches for evaluating models under concept drift.
  8. [8]
    Rabanser, S., Günnemann, S., & Lipton, Z. (2019). Failing Loudly: An Empirical Study of Methods for Detecting Dataset Shift. NeurIPS 32.Empirical research on methods for detecting and characterizing distribution shifts; shift detection needs further analysis to determine business or model-performance harm.
  9. [9]
    Office of the Comptroller of the Currency (September 11, 2026). Third-Party Risk Management: Proposed Guidance and Request for Comment.Proposed replacement for existing interagency third-party guidance, included to clarify current-versus-proposed status; not presented as operative final guidance.