Model Risk Management (SR 11-7 in plain language)

The risk framework banks have used for a decade — useful for everyone.

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Three pillars

SR 11-7, decoded

The US Federal Reserve's SR 11-7 guidance (2011) is the de-facto baseline for model risk in banking. Its three pillars apply far beyond finance:

  1. Robust model development & implementation — documented data, assumptions, theoretical grounding.
  2. Independent model validation — a different team / function reviews and challenges the model before use.
  3. Ongoing governance — inventory, periodic re-validation, performance monitoring, escalation procedure.

Map it to your stack:

  • 'Inventory' = your model registry.
  • 'Periodic re-validation' = the monitoring dashboards + retraining triggers from Level 5.
  • 'Independent validation' = a second-team review gate in CI/CD.

If you've built Levels 0–5 of this track, you've already built ~70% of an SR 11-7-style program. Document the rest.

Analogy

SR 11-7 is like the structural-engineering code in construction. You don't have to like it, but it's why bridges don't collapse. Voluntary ML projects can borrow the discipline without the cost of full compliance.

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