Over the course of several hundred model validations we have observed a number of recurring themes and challenges that appear to be common to almost every model risk management department. At one time or another, every model risk manager will puzzle over questions around whether an application is a model, whether a full-scope validation is necessary, how to deal with challenges surrounding “black box” third-party vendor models, and how to elicit assistance from model owners. This series of blog posts aims to address these and other related questions with what we’ve learned while helping our clients think through these issues.
As model validators, we frequently find ourselves in the middle of debates between spreadsheet owners and enterprise risk managers over the question of whether a particular computing tool rises to the level of a “model.” To the uninitiated, the semantic question, “Is this spreadsheet a model?” may appear to be largely academic and inconsequential. But its ramifications are significant, and getting the answer right is of critical importance to model owners, to enterprise risk managers, and to regulators.
Many of the models we validate on behalf of our clients are developed and maintained by third-party vendors. These validations present a number of complexities that are less commonly encountered when validating “home-grown” models.
Notwithstanding these challenges, the OCC’s Supervisory Guidance on Model Risk Management (OCC 2011-12) specifies that “Vendor products should nevertheless be incorporated into a bank’s broader model risk management framework following the same principles as applied to in-house models, although the process may be somewhat modified.”
Though not its intent, model validation can be disruptive to model owners and others seeking to carry out their day-to-day work. We have performed enough model validations over the past decade to have learned how cumbersome the process can be to business unit model owners and others we inconvenience with what at times must feel like an endless barrage of touch-point meetings, documentation requests and other questions relating to modeling inputs, outputs, and procedures.
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…
When someone asks you what a model validation is what is the first thing you think of? If you are like most, then you would immediately think of performance metrics— those quantitative indicators that tell you not only if the model is working as intended, but also its performance and accuracy over time and compared to others. Performance testing is the core of any model validation and generally consists of the following components:
- Sensitivity Analysis
- Stress Testing
Sensitivity analysis and stress testing, while critical to any model validation’s performance testing, will be covered by a future article. This post will focus on the relative virtues of benchmarking versus back-testing—seeking to define what each is, when and how each should be used, and how to make the best use of the results of each.
In some respects, the OCC 2011-12/SR 11-7 mandate to verify model inputs could not be any more straightforward: “Process verification … includes verifying that internal and external data inputs continue to be accurate, complete, consistent with model purpose and design, and of the highest quality available.” From a logical perspective, this requirement is unambiguous and non-controversial. After all, the reliability of a model’s outputs cannot be any better than the quality of its inputs.