Evaluate your institution’s model risk management framework against the Federal Reserve SR 11-7 / OCC 2011-12 guidance. Scores model development, validation, governance, and inventory practices with gap identification and remediation priorities.
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Scope & reliance — Scoring logic reflects Federal Reserve SR 11-7 (April 2011) and OCC 2011-12 as implemented through examination practice. Scores are self-assessment indicators, not substitutes for a formal internal audit or examiner review. Large bank holding companies subject to CCAR should apply additional SR 15-18 / SR 15-19 expectations. Verify all guidance citations against current primary sources.
Rating Scale: 0: Not in place 1: Ad hoc / informal 2: Partial / developing 3: Mostly compliant 4: Fully compliant
Domain 1Model Development & ImplementationWeight: 30%
Conceptual soundness documentation — theoretical basis documented and peer-reviewed before deployment
SR 11-7 Β§I (Conceptual Soundness)
Data quality processes — input data validated for completeness, accuracy, and relevance; gaps documented
SR 11-7 Β§I (Data Quality)
Model testing — back-testing, benchmarking against alternative models, and sensitivity analysis performed
SR 11-7 Β§I (Testing)
Assumptions documented — all material assumptions identified, stress-tested, and justified with quantitative or qualitative support
SR 11-7 Β§I (Assumptions)
Ongoing monitoring — model performance tracked post-deployment against performance benchmarks; deterioration triggers remediation
SR 11-7 Β§III (Ongoing Monitoring)
Change management — material model changes (methodology, data, use) follow a formal change process with documentation and re-validation
SR 11-7 Β§I (Change Management)
Vendor model oversight — third-party and vendor models subject to same MRM standards as internally developed models
SR 11-7 Β§IV (Vendor Models)
Inventory completeness — all models formally identified and tracked in a central inventory accessible to model risk and senior management
SR 11-7 Β§IV (Model Inventory)
Domain 2Model ValidationWeight: 35%
Validation independence — validators are organisationally independent of model development team; no significant self-review
SR 11-7 Β§II (Independence)
Conceptual review — validation independently evaluates the theoretical basis, methodology, and mathematical derivation of the model
SR 11-7 Β§II (Conceptual Soundness Review)
Outcomes analysis — validation compares model outputs to actual outcomes through back-testing, benchmarking, or challenger model analysis
SR 11-7 Β§II (Outcomes Analysis)
Sensitivity testing — validation tests model performance under stressed scenarios and edge cases to assess robustness
SR 11-7 Β§II (Sensitivity Analysis)
Documentation review — validation reviews and issues a written opinion on all model documentation including assumptions, limitations, and intended use
SR 11-7 Β§II (Documentation)
Ongoing validation — periodic revalidation triggered by performance deterioration, material changes, passage of time, or significant market shifts
SR 11-7 Β§II (Ongoing Review)
Validation findings tracked — MRAs, validation exceptions, and outstanding findings are formally tracked to remediation with target dates and owners
SR 11-7 Β§II (Findings Management)
Domain 3Governance & ControlsWeight: 25%
Board / senior management oversight — board approves MRM policy, receives periodic model risk reporting, and reviews material model risk exposures
SR 11-7 Β§III (Governance)
MRM policy — written policy approved by board or senior management covering scope, model definition, risk tiering, and responsibilities
SR 11-7 Β§III (Policies)
Model tiering — models are risk-tiered (e.g. high/medium/low) based on materiality, complexity, and breadth of use; tiering drives validation depth
SR 11-7 Β§III (Risk Tiering)
Findings escalation — validation findings are escalated to appropriate management levels based on severity; critical issues reach CRO or board
SR 11-7 Β§III (Escalation)
Audit coverage — internal audit independently reviews the MRM programme, validation function, and model governance on a periodic basis
SR 11-7 Β§III (Internal Audit)
Regulatory findings — prior examiner MRA/MRIA findings related to model risk are tracked, remediated on schedule, and reported to the board
Centralised inventory — all models registered with model owner, purpose, tier, validation status, and approval date in a centrally maintained system
SR 11-7 Β§IV (Model Inventory)
Documentation standards — model documentation templates enforced; development and validation reports follow a consistent format across the portfolio
SR 11-7 Β§IV (Documentation)
Usage controls — production models are accessed only through controlled, tested processes; unauthorised use or parameter overrides are prevented and logged
SR 11-7 Β§IV (Usage Controls)
Decommissioning — retired or replaced models are formally decommissioned, removed from inventory with rationale documented, and access controls revoked
SR 11-7 Β§IV (Decommissioning)
Domain Scores
Overall MRM Maturity
⚠ Examiner Focus Areas — Typically Most Scrutinised
Validation independence: examiners look for genuine organisational separation from model development, not just nominal independence.
Vendor model oversight: many institutions underestimate their obligation to apply SR 11-7 standards to third-party and vendor-supplied models.
Outcomes analysis: back-testing frequency, challenger model availability, and documentation of out-of-sample performance are common MRA triggers.
Ongoing monitoring: lack of systematic post-deployment tracking is a frequent source of examiner findings, particularly for high-tier models.
CCAR/stress testing models (large BHCs): SR 15-18 / SR 15-19 apply heightened expectations on top of SR 11-7 for BHC stress testing models.
Priority Gaps (items rated 0 or 1)
Remediation Roadmap
Action
Domain
Priority
Horizon
SR 11-7 Ref
Regulatory Sources
Federal Reserve SR 11-7 — Guidance on Model Risk Management (April 4, 2011) — foundational US MRM framework covering model development, validation, governance, and use.
OCC Bulletin 2011-12 — Sound Practices for Model Risk Management (April 4, 2011) — parallel OCC guidance issued jointly; applicable to all national banks and federal savings associations.
Federal Reserve / OCC SR 11-7 Interagency FAQ and Clarifications — scope clarifications covering vendor models, model definition, and proportionality for community banks.
Basel Committee on Banking Supervision — Principles for the Sound Management of Operational Risk (2011) — recognises model risk as a component of operational risk.
Federal Reserve Supervisory Letters SR 15-18 / SR 15-19 — CCAR model risk management expectations for large bank holding companies and FBOs above $50 billion in total assets.