Managing Model Risk & Internal Controls
Build a model risk management and internal control framework that keeps up with AI-enabled decisioning, regulatory expectations and your growth strategy.
Model risk is no longer limited to scorecards and ALM models. AI-driven underwriting, marketing, pricing and fraud analytics all create risk that supervisors expect you to identify, control and monitor. Cicrim helps translate policy language into a living, exam-ready framework that fits your scale.
A modern model risk management framework for AI-enabled banking.
We organize model risk and internal controls around three practical building blocks: Policy & governance, inventory & lifecycle, and validation & monitoring. Each can be right-sized for community and regional institutions without diluting control.
1. Policy & governance
Define the rules of the road
Clarify which tools count as models, how they are approved, and who is accountable. We help align your policy with OCC/Fed/FDIC guidance, SR letters and your internal risk appetite and RAS.
2. Inventory & lifecycle
Know what you depend on
Build a single source of truth for models and critical tools, including vendor and shadow models, so you can track ownership, purpose, data, risk rating and validation status across their lifecycle.
3. Validation & monitoring
Prove that models work as expected
Create fit-for-purpose testing, documentation and monitoring routines that satisfy examiners without overwhelming lean risk teams, including explainability, back-testing, challenger models and performance monitoring.
Services
- Model risk policy and governance framework design
- Model inventory creation and risk rating methodology
- Documentation templates for traditional and AI/ML models
- Model validation planning and independent review support
- Ongoing monitoring metrics and dashboards
- Control mapping across the three lines of defense
- Integration with fair-lending, UDAAP and compliance programs
- Training for boards, credit committees and model owners
We support models across your institution, including:
- Consumer and small business credit models
- Pricing and profitability models
- Fraud, AML and transaction monitoring analytics
- Marketing and next-best-action models
- ALM, liquidity and interest rate risk models
- Stress testing and scenario analysis
- Vendor and third-party models embedded in platforms
- Key non-model tools with model-like risk profiles