The Federal Reserve, OCC, and FDIC have issued revised interagency guidance that fundamentally changes the model risk management standard. The new guidance moves away from prescriptive requirements toward a risk-based, institution-tailored approach calibrated to each organization's size, complexity, and model risk profile. The guidance explicitly states that non-compliance will not result in supervisory criticism, shifting the standard from checklist compliance to demonstrated sound governance. Generative AI and agentic AI models are outside the guidance's current scope. AntePartners' framework is already aligned to the new standard.
We don’t create dependency. Weekly review sessions grow your team’s acumen throughout. At close, you receive a reusable intake checklist and documented frameworks, so every future cycle can be run internally without re-engaging outside consultants.
Our engagement model is built around growing your team alongside us, not around us. Every deliverable is explained, every methodology is documented, and your team leads the process from day one.
Three senior experts in 90 days replaces large junior teams for 6+ months, at significantly lower total cost and with far greater knowledge retention inside your organization.
Remediation costs for informal supervisory findings, MOUs, Consent Orders, and formal enforcement actions routinely exceed the original compliance investment by 5–10×. Prevention is always cheaper, and a team that understands the framework is your best long-term defense.
A consent order restricts business activities, triggers enhanced supervision, and can freeze growth initiatives for years. Durable compliance capability is the only reliable protection.
Our dashboards flag model behavior changes in real time, so your team addresses issues proactively, building confidence with regulators through demonstrated ongoing governance rather than reactive responses.
SR 26-2 requires practices proportionate to the institution's size, complexity, and model risk profile. Generic frameworks applied uniformly across all models, regardless of materiality, do not meet the new standard.
No disciplined methodology for assessing model materiality, sequencing validation, or calibrating oversight to inherent risk. The result is either over-engineered governance on immaterial models or under-engineered governance on material ones.
SR 26-2 emphasizes effective challenge by objective experts with organizational standing to effect change. Validation functions without genuine independence or authority to act on findings do not satisfy this standard.
Comparative performance analysis, back-testing, and ongoing monitoring vary team-to-team, making review and validation far harder than it needs to be and leaving institutions unable to demonstrate systematic oversight.
Under SR 26-2, documentation must support effective model risk management, including continuity of operations and remediation tracking. Fragmented or inconsistent documentation creates gaps that examiners identify immediately.
We assess your model inventory by materiality, calibrate the depth of governance to each model's inherent risk and exposure, and build a framework that is proportionate, defensible, and genuinely sound rather than uniformly applied.
Kupiec, Christoffersen, and Traffic Light methodology, sequenced to assess materiality and determine appropriate oversight at each level, aligned to SR 26-2's risk-based approach.
Our practitioners have the technical expertise, independence, and organizational standing that SR 26-2 requires of effective challenge. Every review is conducted by people who can identify model limitations and effect change, not just document findings.
Portfolio composition, statistical analysis, market condition performance, and business impact produced consistently, with the documentation structure that examiner review requires.
Output documentation is structured to the criteria SR 26-2 specifies: supporting continuity of operations, tracking recommendations and exceptions, and enabling effective model remediation. Ready for independent validator review on day 90.
Structured sessions with business, risk, technology, model owner, and model validation group leads, capped at 1 hour each to minimize client burden.
Model execution results reviewed for completeness. Policy documents, org charts, and IT schematics gathered to support SR 26-2 governance documentation.
Continuous feedback on artifact gaps so your team can address issues in parallel, no surprises at the end.
Client-specific parameters and historical periods loaded into the AntePartners platform.
Statistical backtesting of model exceptions against regulatory thresholds.
Conditional coverage testing to assess independence of exceptions over time.
Standardized color-banded performance classification aligned to BIS guidance.
Model performance assessed against stress events and market dislocations.
Limits, thresholds, and caps evaluated against model outputs with narrative generation.
Structured walkthroughs with business and risk officers to demonstrate progress and build acumen.
Comprehensive output document structured to SR 26-2 documentation standards, ready for regulator submission.
Reusable checklist to ensure future testing cycles can be executed efficiently without re-engaging AntePartners.
Optional: dashboards configured for daily, weekly, monthly, and quarterly model performance tracking.
