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Offering 04 · Model Risk Management

SR 26-2 Changed the Approach.
We Help You Apply It.

AntePartners performs the testing, analysis, and documentation that model assessment requires. Your teams can focus on interpretation, effective challenge, and risk decisions, supported by senior practitioners who perform the assessment work. When we are done, you own the process.

Discuss your priorities
See how we work

For U.S. banks and the U.S. operations of international banks.

Quantitative assessment   ·   Organized supporting evidence   ·   Independent validation support

Where we help

Technical work that supports
model decisions.

A new or changing model

Assess a model before introduction or transition. Compare methodologies and settings, investigate limitations, and organize the evidence needed for informed review.

An assessment or remediation backlog

Add experienced delivery capacity when testing, analysis, or documentation is holding up decisions. Connect the work to the underlying issue and the institution’s priorities.

What the guidance means for you

The Implications Depend on Who You Are.

Banks above $30 billion

Review how model risk practices reflect the institution’s model use, exposure, and complexity. Identify where assessment and documentation work can support proportionate oversight.

Smaller banking organizations

The guidance may be relevant in specified circumstances involving significant model risk. Assess the institution and applicable supervisory context rather than assuming a universal requirement.

Banks with open findings

Determine how the guidance relates to the specific finding and response with the relevant supervisor. A guidance change does not itself demonstrate that the underlying issue has been resolved.

Investment and asset managers

The framework may inform useful practices, but significant model use alone does not place every investment manager within this interagency banking guidance. Scope advisory work against the entity’s applicable obligations.

Where practices fall short

The Governance Gap Problem.

Practices disconnected from model risk

Assess the institution and model use, then tailor the work to the actual risk profile.

Fragmented decision frameworks

Document the basis for methodologies, parameters, and assessment priorities so decisions can be understood and challenged.

Challenge without usable evidence

Organize the methods, results, limitations, and supporting records for independent review; clarify roles and responsibilities.

Inconsistent outcomes analysis

Use model-appropriate testing and consistent presentation to help reviewers compare results and understand limitations.

Documentation spread across teams

Compile a structured package indexed to applicable guidance, with evidence locations and remaining gaps visible.

What we deliver

From model results to
evidence reviewers can use.

Model testing and performance analysis

Analyze client-generated model results using methods appropriate to the model, its purpose, and the available data.

Methodology and parameter comparisons

Evaluate alternative approaches and settings, document tradeoffs, and explain the basis for recommendations.

Stress-period and business impact analysis

Examine performance through relevant market conditions and assess implications for portfolios, counterparties, and risk decisions.

Structured documentation and review support

Bring assumptions, methods, results, limitations, and supporting evidence together, then work through questions with your teams.

For applicable VaR assessments, testing may include Kupiec, Christoffersen, and traffic-light analyses. The test plan is selected for the model being assessed; the same statistical tests do not fit every model.

Documentation designed for review

Bring the work together.
Make the evidence easier to follow.

Model documentation can be dispersed across business, risk, technology, and validation teams. We compile the relevant material into a structured package indexed to applicable regulatory guidance, helping reviewers locate evidence, assess coverage, and identify gaps.

Understand the model

Purpose, methodology, assumptions, data, implementation, and limitations presented in a coherent sequence.

Follow the analysis

Testing, comparisons, findings, and supporting material organized around the conclusions they inform.

Focus the challenge

Reviewers can assess the work and raise substantive questions with less time spent reconstructing the documentation.

A well-organized package supports rigorous validation. It does not replace independent judgment or eliminate the need for follow-up analysis.

How we work

Clear responsibilities.
Visible progress.

01 · Define

Agree the assessment.

Confirm model scope, parameters, historical periods, data requirements, roles, and intended deliverables. Establish client execution and data-transfer responsibilities.

ResultAn agreed assessment plan and readiness checklist.
  • Stakeholder interviews and artifact collection.
  • Data-completeness and documentation-gap review.
  • Parameters, historical periods, and configuration agreed.

02 · Produce

Test, analyze, and document.

Perform the scoped work and share emerging observations through regular updates. Address data gaps and connect results to the model’s purpose and business use.

ResultAn integrated assessment with supporting analysis and evidence.
  • Model-appropriate test execution and result review.
  • Portfolio, market-condition, and business-impact analysis.
  • Regular client walkthroughs of results and open questions.

03 · Support

Work through review and transition.

Explain the analysis, respond to challenge, perform agreed supplemental work, and support practical transition planning and knowledge transfer.

ResultA reviewed assessment and clearer next steps for the institution.
  • Memorandum and supporting evidence assembled.
  • Independent validation questions and agreed supplemental work supported.
  • Intake checklist, methods, and operating knowledge transferred.

The bank retains model-use decisions, governance ownership, and independent validation responsibilities. AntePartners’ review of its own deliverables is quality assurance, not a substitute for independent validation.

An example engagement

A scoped assessment.
A practical delivery target.

For a suitably scoped engagement with the necessary data and model runs available, our delivery model targets an assessment by Day 60, followed by review, challenge, and transition support through Day 90.

Timing is agreed after assessing model complexity, data readiness, client availability, and validation needs. These are delivery targets, not guarantees of model approval, completed transition, or regulatory closure. Ongoing monitoring and recurring back-testing can be scoped separately.

Current regulatory context

A proportionate approach
to model risk.

SR 26-2 emphasizes a risk-based approach tailored to the institution and its model use. We help teams assess their practices and organize evidence in light of the applicable guidance and their specific risks.

The revised guidance replaces SR 11-7 and SR 21-8. It is most relevant to banking organizations above $30 billion in assets, with specified circumstances in which it may also be relevant to smaller organizations. Generative and agentic AI are outside its scope; appropriate governance for those systems remains a separate consideration. Read the official guidance

The business case

The Business Case:
Less production burden. More informed review.

Model testing

Automation supports repeatable calculations and analysis, with senior review and methods chosen for the model being assessed.

Repeat back-testing

A configured approach and reusable inputs can reduce setup for subsequent periods. Scope and timing depend on data and model changes.

Validation preparation

An organized memorandum helps validators locate evidence and focus on substantive challenge. It does not replace their independent assessment.

Lower staffing overhead

A typical team of three senior practitioners concentrates expertise and production in the same people. No junior resources are deployed.

Institutional knowledge transfer

Weekly discussions, documented methods, and a reusable intake checklist help the client sustain the process.

Monitoring as an additional service

Dashboards, thresholds, alerts, ownership, and review frequencies can be configured as a separately scoped extension.

Framework capabilities

What the Framework Delivers.

Automated testing engine

Repeatable execution of appropriate tests from client-generated results, supported by human review and documented assumptions.

Guidance-indexed memorandum

Methods, analysis, conclusions, limitations, governance, and supporting evidence in a structured package for review.

Standardized visualization

Charts and tables covering relevant portfolio composition, statistical results, market conditions, and business impact.

Reusable assessment process

An intake checklist, documented configuration, and knowledge transfer support subsequent cycles.

Continuous performance monitoring

Optional dashboards and alerts configured to agreed indicators and reporting frequencies, with clear human review responsibilities.

What you receive

Tangible Deliverables.

Comprehensive model assessment memorandum

Model documentation, development materials, relevant business analysis, governance and controls, issues, and reporting, with supporting graphs, tables, and narrative.

Model validation intake checklist

A reusable checklist for relevant artifacts, stakeholder input, model results, and documentation before assessment and validation.

Model inventory for the agreed scope

A record of models covered, relevant methods and settings, ownership, risk classification, and review status, as agreed in the engagement.

Optional continuous monitoring dashboard

Configured views and alerts as an additional service, with frequency, thresholds, and operating responsibilities defined.

Connected expertise

When model risk is part
of a wider delivery issue.

Regulatory remediation

Connect model assessment and evidence preparation to corrective actions when a regulatory finding needs to be addressed.

Regulatory remediation

Program recovery

Restore delivery discipline when the wider initiative has stalled, ownership is unclear, or dependencies are blocking progress.

Program recovery

RELATED READING

Preparing for independent model validation

Connect model testing, analysis, limitations and documentation in a complete, traceable evidence package.

Read Mat Small’s perspective on model validation readiness

Get In Touch

Discuss your model risk priorities.

Tell us whether you are assessing a model, preparing for validation, or addressing a finding. We can discuss the work needed and how your team would engage with ours. A high-level description is enough to start. Please do not include confidential supervisory information or sensitive bank documents in the initial inquiry.