The Model Has Changed — How Banking Organizations Should Respond

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The Model Has Changed — How Banking Organizations Should Respond
By
Protiviti

Where Banking Organizations Should Direct Focus

In an exciting evolution of model risk management (MRM), banking organizations are now empowered to embrace a more flexible, principles-based approach. This shift from rigid compliance to risk-proportionate expectations allows institutions to customize their MRM frameworks according to their unique size, complexity and model usage. The real advantage here is the ability to concentrate on the most significant risks while adeptly navigating the intricate world of advanced analytics, artificial intelligence (AI) and machine learning (ML). As these technologies become increasingly prevalent in financial models, the need for robust governance frameworks has never been more critical to tackle their inherent complexities.

The urgency of this transition is heightened by recent systemic stress events and liquidity crises, alongside the rapid emergence of generative and agentic AI, which introduces new challenges for the banking sector. Organizations are encouraged to refine their skills in strategic framework design, risk-based governance and adaptive validation practices. Evaluating current MRM practices and aligning them with this new guidance helps institutions implement targeted controls that reflect the complexity and materiality of their models. Practical strategies include revisiting model inventories, enhancing oversight of third-party models, and adopting a risk-tiering approach to prioritize the most impactful areas.

Key Takeaways:

  • A shift toward a risk-based, principles-driven approach replaces prescriptive compliance.
  • Tailored governance is essential for managing the complexity and opacity of AI and ML models.
  • Organizations should reassess their MRM frameworks to focus on material risks.
  • Effective MRM practices enhance resilience, equipping firms to tackle emerging risks and technologies.