What is Model Risk Management?
Model Risk Management (MRM) is a discipline focused on identifying and mitigating risks associated with using quantitative models in business decisions. Originally developed in financial services (SR 11-7), it's increasingly applied to AI and machine learning models.
Sources of Model Risk
Model Error
- Incorrect assumptions
- Mathematical errors
- Data quality issues
- Implementation bugs
Misuse
- Using models outside intended scope
- Misinterpreting outputs
- Over-reliance on models
External Changes
- Market regime changes
- Data drift
- Concept drift
MRM Framework
Model Inventory
- Catalog all models
- Classify by risk tier
- Track model lineage
Model Development
- Documentation standards
- Development controls
- Testing requirements
Model Validation
- Independent review
- Conceptual soundness
- Outcome analysis
- Benchmarking
Ongoing Monitoring
- Performance tracking
- Drift detection
- Periodic review
- Change management
Regulatory Guidance
Financial Services
- SR 11-7 (Federal Reserve)
- OCC 2011-12
- Basel requirements
AI-Specific
- EU AI Act
- NIST AI RMF
- Industry guidelines
AI/ML Considerations
- Explainability requirements
- Bias and fairness testing
- Continuous monitoring
- Version control
- Reproducibility