Concern 896 · Working draft · editorial review in progress

Model risk management (MRM)

Model risk management is the work of identifying, testing and controlling harm from models that are wrong, poorly used or no longer suited to their task.

Understanding the concern

A model can fail because of its design, its data or the way people interpret its output. Managing that risk means keeping an inventory, assigning responsibility, checking limitations and watching performance over time. Generative AI adds challenges because a fluent answer is harder to evaluate than a single numerical estimate.

Banking guidance is often cited here, but its scope matters. US SR 26-2 replaced SR 11-7 in April 2026 and excludes generative and agentic AI from its scope. Organizations can still learn from model-governance practices without claiming that this guidance directly covers every chatbot. Think of an equipment inspection program: useful habits can transfer, but different equipment needs different tests.

An example

A company assumes its existing spreadsheet-model review fully addresses an AI assistant that can generate advice and use tools.

Illustrative unless identified as a documented case.

Words in plain English

AI
Software that learns patterns from examples or uses rules to perform tasks such as recognizing images or generating text. It can make mistakes and does not understand every situation as a person would.
Agent
An AI system that can choose and carry out several steps toward a goal, using the tools and access people give it.
Model
The learned part of an AI system. It uses patterns found during training to produce an answer or prediction.
Model risk management
The work of identifying, checking, and managing the risks of using models in decisions.

Evidence and its limits

SR 26-2's scope excludes generative and agentic AI. NIST's profile is voluntary guidance, not an extension of that banking supervisory letter.

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Broader frameworks and background

These resources provide context. They do not establish every claim in this concern.

A question to discuss

Which risks does the current review actually cover, and what additional checks does this AI use require?

Keep track of different views, what needs checking, and any next step in your own discussion notes.

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Principles for the conversation

Before you finish · reflect together

Virtues and principles to consider

Virtues are qualities we practice in how we treat people and make choices. They are not scores for judging someone. Use these ideas to explore what a thoughtful response could look like.

Trustworthiness

Trustworthiness means giving people good reasons to rely on you. It grows when promises, actions, and evidence line up. With AI, a friendly voice or a famous brand is not enough: people need to know what was checked and what could still go wrong.

In practice, keep promises small enough to test, record mistakes, and tell people when the tool's limits affect them. If a service promises human review, make sure a person really has time and authority to review it.

Ask together: What would give the people affected a sound reason to trust this use?

Stewardship

Stewardship means caring for resources and systems that others depend on, including people who will use them later. It looks beyond the benefit of a quick launch.

Plan for maintenance, energy use, data protection, and eventual shutdown. Ask who will look after the tool when the original team moves on and how future users can avoid inheriting hidden costs.

Ask together: What are we responsible for caring for over time?

Prudence

Prudence means using careful judgment before and during action. It balances worthwhile opportunities with the need to avoid harm that could have been anticipated.

Start with a limited trial, set stopping points, and prefer choices that can be undone when uncertainty is high. Review what happens rather than assuming the original plan remains sound.

Ask together: What is a careful next step, and when should we stop or change course?

Editorial ratings

These are editorial judgments from the register, not measured probabilities or predictions about your situation.

Severity
Serious · 3/5
Likelihood
Widely observed · 4/5
Time horizon
Now
Register risk score
12
About the register and scoring →
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