Though the terms are often used interchangeably in casual conversation, machine learning is a subset of artificial intelligence. Simply put, ML is the process of getting a computer to learn the properties of one dataset and generalizing this “knowledge” on other datasets.

ML Financial Models

ML models have crept into virtually every corner of banking and finance — from fraud and money-laundering prevention to credit and prepayment forecasting, trading, servicing, and even marketing. These models take various forms (see Table 1, below). Modelers base their selection of a particular ML technique on a model’s objective and data availability.   

Table 1. ML Models and Application in Finance

Model Application
Linear Regression Credit Risk; Forecasting
Logistic Regression Credit Risk
Monte Carlo Simulation Capital Market; (ALM)
Artificial Neutral Networks Score Card and AML
Decision Trees Regression Models (Random Forest, Bagging) Score Card
Multinomial Logistic Regression Prepayment Projection
Deep Learning Prepayment Projection
Time Series Model Capital Forecasting; Macroeconomics Forecasting Model
Linear Regression with ARIMA Errors Capital Forecasting
Factor Models Short Rate Evolution
Fuzzy Matching AML; OFAC
Linear Discriminant Analysis (LDA) AML; OFAC
K Means Clustering AML; OFAC


ML models require large datasets relative to conventional models as well as more sophisticated computer programing and econometric/statistical skills. ML model developers are required to have deep knowledge about the ML model they want to use, its assumptions and limitations, and alternative approaches.


ML Model Risk

ML models present many of the same risks that accompany conventional models. As with any model, errors in design or application can lead to performance issues resulting in financial losses, poor decisions, and damage to reputation.

ML is all about algorithms. Failing to understand the mathematical aspects of these algorithms can lead to adopting inefficient optimization algorithms without knowing the nature or the interpretation of the optimization being solved. Making decisions under these circumstances increases model risk and can lead to unreliable outputs.

As sometimes befalls conventional regression models, ML models may perform well on the training data but not on the test data. Their complexity and high dimensionality makes them especially susceptible to overfitting. The poor performance of some ML models when applied beyond the training dataset can translate into a huge source of risk.

Finally, ML models can give rise to unintended consequences when used inappropriately or incorrectly. Model risk is magnified when the goal of a ML model’s algorithm is not aligned with the business problem or doesn’t consider all relevant considerations of the business problem. Model risk also arises when an ML model is used outside the environment for which it was designed. These risks include overstated/understated model outputs and lack of fairness. Table 2, below, presents a more comprehensive list of these risks.

Table 2. Potential risk from ML models

Bias toward protected groups
Use of poor-quality data
Job displacement
Models may produce socially unacceptable results
Automation may create model governance issues


Managing ML Model Risk

managing ML model risk

It may seem self-evident, but the first step in managing ML model risk consists of reliably  identifying every model in the inventory that relies on machine learning. This exercise is not always as straightforward as it might seem. Successfully identifying all ML models requires MRM departments to incorporate the right information requests into their model determination or model assessment forms. These should include questions designed to identify specific considerations of ML model techniques, algorithms, platforms and capabilities. MRM departments need to adopt a consistent but flexible definition about what constitutes an ML model across the institution. Models developers, owners and users should be trained in identifying ML models and those features that need to be reported in the model identification assessment form.

MRM’s next step involves risk assessing ML models in the inventory. As with traditional models, ML models should be risk assessed based on their complexity, materiality and frequency of use. Because of their complexity, however, ML models require an additional level of screening in order to account for data structure, level of algorithm sophistication, number of hyper-parameters, and how the models are calibrated. The questionnaire MRM uses to assess the risk of its conventional models often needs to be enhanced in order to adequately capture the additional risk dimensions introduced by ML models.

Managing ML model risk also involves not only ensuring that a clear model development and implementation process is in place but also that it is consistent with the business objective and the intended use of the models. Thorough documentation is important for any model, but the need to describe model theory, methodology, design and logic takes on added importance when it comes to ML models. This includes specifying the methodology (regression or classification), the type of model (linear regression, logistic regression natural language processing, etc.), the resampling method (cross-validation, bootstrap) and the subset selection method such as backward, forward or stepwise selection. Obviously, simply stating that the model “relies on a variety of machine learning techniques” is not going to pass muster.

As with traditional models, developers must document the data source, quality and any transformations that are performed. This includes listing the data sources, normalization and sampling techniques, training and test data size, the data dimension reduction technique (principal component, partial least squares, etc.) as well as controls around them. An assessment of the risk around the utilization of certain data should also be assessed.

A model implementation plan and controls around the model should be also be developed.

Finally, all model performance testing should be clearly stated, and the results documented. This helps assess whether the model is performing as intended and in line with its design and business objective. Limitations and calibrations around the models should also be documented.

Like traditional models, ML models require independent validation to ensure they are sound and performing as intended and to identify potential limitations. All components of ML models should be subject to validation, including conceptual soundness, outcomes analysis and ongoing monitoring.

Validators can assess the conceptional soundness of an ML model by evaluating its design and construction, focusing on the theory, methodology, assumptions and limitations, data quality and integrity, hyper-parameter calibration and overlays, bias and interpretability.

Validators can assess outcomes analysis by checking whether the model outputs are appropriate and in line with a priori expectations. Results of the performance metrics should also be assessed for accuracy and degree of precision. Performance metrics for ML models vary by model type. Similar to traditional predictive models, common performance metrics for ML models include the mean-squared-error (MSE), Gini coefficient, entropy, the confusion matrix, and the receiver operating characteristic (ROC) curve.

Outcomes analysis should also include out-of-sample testing, which can be conducted using cross-validation techniques. Finally, ongoing monitoring should be reviewed as a core element of the validation process. Validators should evaluate whether model use is appropriate given changes in products, exposures and market conditions. Validators should also ensure performance metrics are being monitored regularly based on the inherent risk of the model and frequency of use. Validators should ensure that a continuous performance monitoring plan exists and captures the most important metrics. Also, a change control document and access control document should be available.  

The principles outlined above will sound familiar to any experienced model validator—even one with no ML training or experience. ML models do not upend the framework of MRM best practices but rather add a layer of complexity to their implementation. This complexity requires MRM departments in many cases to adjust their existing procedures to property identify ML models and suitably capture the risk emerging from them. As is almost always the case, aggressive staff training to ensure that their well-considered process enhancements are faithfully executed and have their desired effect.