Align model governance with materiality
Questions about how often a model should be validated can overshadow a more important issue: how much risk the model creates for the institution.
A useful model governance framework starts with an inventory, materiality assessment, and risk-ranking process. These concepts are not new, but they are becoming increasingly important as banking institutions expand their use of models across credit, liquidity, asset/liability management, anti-money laundering, and financial reporting functions. These steps help leaders understand where models are used, which decisions they influence, and what could happen if their output is unreliable.
A risk-based model risk management approach allows financial institutions to focus more attention on models that affect significant financial reporting, capital, liquidity, credit, or strategic decisions. Lower-risk models may warrant a more proportionate level of oversight. In other words, the framework helps focus attention on the models that have the greatest influence on decision-making while allowing institutions to scale oversight activities for lower-risk applications.
Validation also provides value beyond meeting a recurring requirement. Testing data quality, evaluating assumptions, confirming calculations, assessing performance, and identifying weaknesses can improve confidence in the information leaders use.