Model risk management is a necessary undertaking for which model owners must prepare on a regular basis. Model risk managers frequently struggle to strike an appropriate cost-benefit balance in determining whether a model requires validation, how frequently a model needs to be validated, and how detailed subsequent and interim model validations need to be. The extent to which a model must be validated is a decision that affects many stakeholders in terms of both time and dollars. Everyone has an interest in knowing that models are reliable, but bringing the time and expense of a full model validation to bear on every model, every year is seldom warranted. What are the circumstances under which a limited-scope validation will do and what should that validation look like? We have identified four considerations that can inform your decision on whether a full-scope model validation is necessary:
- What about the model has changed since the last full-scope validation?
- How have market conditions changed since the last validation?
- How mission-critical is the model?
- How often have manual overrides of model output been necessary?
What Constitutes a Model Validation
Comprehensive model validations consist of three main components: conceptual soundness, ongoing monitoring and benchmarking, and outcomes analysis and back-testing. A comprehensive validation encompassing all these areas is usually required when a model is first put into use. Any validation that does not fully address all three of these areas is by definition a limited-scope validation. 1 Comprehensive validations on ‘black box’ models developed and maintained by third-party vendors are therefore problematic because the mathematical code and formulas are not typically available for review (in many cases a validator can only hypothesize the cause and effect relationships between the inputs and outputs based on a reading of the model’s documentation). Ideally, regular comprehensive validations are supplemented by limited-scope validations and outcomes analyses on an ongoing, interim basis to ensure that the model performs as expected.
Key Considerations for Model Validation
There is no ‘one size fits all’ question for determining how often a comprehensive validation is necessary, versus when a limited-scope review would be appropriate. Beyond the obvious time and cost considerations, model validation managers would benefit from asking themselves a minimum of four questions in making this determination:
Question 1: What about the model has changed since the last full-scope validation?
Many models layer economic assumptions on top of arithmetic equations. Most models consist of three principal components:
- inputs (assumptions and data)
- processing (underlying mathematics and code that transform inputs into estimates)
- output reporting (processes that translate estimates into useful information)
Changes to either of the first two components are more likely to require a comprehensive validation than changes to the third component. A change that materially impacts how the model output is computed, either by changing the inputs that drive the calculation or by changing the calculations themselves, is more likely to merit a more comprehensive review than a change that merely affects how the model’s outputs are interpreted.
For example, say I have a model that assigns a credit rating to a bank’s counterparties on a 100-point scale. The requirements the bank establishes for the counterparty are driven by how the model rates the counterparty. Say, for example, that the bank lends to counterparties that score between 90 and 100 with no restrictions, between 80 and 89 with pledged collateral, between 70 and 79 with delivered collateral, and does not lend to counterparties scoring below a 70. Consider two possible changes to the model:
- Changes in model calculations that result in what used to be a 65 now being a 79.
- Changes in grading scale that result in a counterparty that receives a rating of 65 now being deemed creditworthy.
While the second change impacts the interpretation of model output and may require only a limited-scope validation to determine whether the amended grading scale is defensible, the first change is almost certain to require that the validator go deeper ‘under the hood’ for verification that the model is working as intended. Assuming that the inputs did not change, the first type of change may be the result of changes to assumptions (e.g., weighting schemes) or simply a revision to a perceived calculation error. The second is a change on the reporting component, where a comparison of the model’s forecasts to those of challenger models and back-testing with historical data may be sufficient for validation. Not every change that affects model outputs necessarily requires a full-scope validation. The insertion of recently updated economic forecasts into a recently validated model may require only a limited set of tests to demonstrate that changes in the model estimates are consistent with the new economic forecast inputs. The magnitude of the impact on output also matters. Altering several input parameters that results in a material change to model output is more likely to require a full validation.
Question 2: How have market conditions changed since the last validation?
Even models that do not change at all require periodic, full-scope validations because macroeconomic conditions or other external factors call one or more of the model’s underlying assumptions into question. The 2008 global financial crisis is a perfect example. Mortgage credit and prepayment models prior to 2008 were built on assumptions that appeared reasonable and plausible based on market observations prior to 2008. Statistical models based solely on historical data before, during, or after the crisis are likely to require full-scope validations as their underlying datasets are expanded to capture a more comprehensive array of observed economic scenarios. It doesn’t always have to be bad news in the economy to instigate model changes that require full-scope validations. The federal funds rate has been hovering near zero since the end of 2008. With a period of gradual and sustained recovery potentially on the horizon, many models are beginning to incorporate rising interest rates into their current forecasts. These foreseeable model adjustments will likely require more comprehensive validations geared toward verifying that model outputs are appropriately sensitive to the revised interest rate assumptions.
Question 3: How mission-critical is the model?
The more vital the model’s outputs are to financial statements or mission-critical business decisions, the greater the need for frequent and detailed third-party validations. Model risk is amplified when the model outputs inform reports that are provided to investors, regulators, or compliance authorities. Particular care should be given when deciding whether to partially validate models with such high-stake outputs. Models whose outputs are used for internal strategic planning are also important. That being said, some models are more critical to a bank’s long-term success than others. Ensuring the accuracy of the risk algorithms used for DFAST stress testing is more imperative than the accuracy of a model that predicts wait times in a customer service queue. Consequently, DFAST models, regardless of their complexity, are likely to require more frequent full-scope validations than models whose results likely undergo less scrutiny.
Question 4: How often have manual overrides of model output been necessary?
Another issue to consider revolves around the use of manual overrides to the model’s output. In cases where expert opinion is permitted to supersede the model outputs on a regular basis, more frequent full-scope validations may be necessary in order to determine whether the model is performing as intended. Counterparty credit scoring models, cited in our earlier example, are frequently subjected to manual overrides by human underwriters to account for new or other qualitative information that cannot be processed by the model. The decision of whether it is necessary to revise or re-estimate a model is frequently a function of how often such overrides are required and what the magnitude of these overrides tends to be. Models that frequently have their outputs overridden should be subjected to more frequent full-scope validations. And models that are revised as a result of numerous overrides should also likely be fully validated, particularly when the revision includes significant changes to input variables and their respective weightings.
Full or Partial Model Validation?
Model risk managers need to perform a delicate balancing act in order to ensure that an enterprise’s models are sufficiently validated while keeping to a budget and not overly burdening model owners. In many cases, limited-scope validations are the most efficient means to this end. Such validations allow for the continuous monitoring of model performance without bringing in a Ph.D. with a full team of experts to opine on a model whose conceptual approach, inputs, assumptions, and controls have not changed since its last full-scope validation. While gray areas abound and the question of full versus partial validation needs to be addressed on a case-by-case basis, the four basic considerations outlined above can inform and facilitate the decision. Incorporating these considerations into your model risk management policy will greatly simplify the decision of how detailed your next model validation needs to be. An informed decision to perform a partial model validation can ultimately save your business the time and expense required to execute a full model validation.
 In the United States, most model validations are governed by the following sets of guidelines: 1) OCC 2011-12 (institutions regulated by the OCC), and 2) FRB SR-11 (institutions regulated by the Federal Reserve). These guidelines are effectively identical to one another. Model validations at Government-sponsored enterprises, including Fannie Mae, Freddie Mac, and the Federal Home Loan Banks, are governed by Advisory Bulletin 2013-07, which, while different from the OCC and Fed guidance, shares many of the same underlying principles.