Having an accurate and up to date inventory of models (whether they are spreadsheet-based or other) is the foundation of any model governance program. Now that you’ve chosen to manage these model risks, what’s the best way to track them?
Creating and maintaining a Model Inventory is simple in concept but much harder in practice. Identifying the existing models to include can be challenging, especially given the fact that the line of business aren’t usually enthusiastic about documenting their model usage. Some model owners would prefer that you just go away, thank you very much. But it’s the “maintain” task that is really difficult. Keeping a model inventory accurate and up to date takes a lot of work. From chasing down various owners and users for updates to reporting on KRIs, it is a thankless job that never ends. Model Inventories are very resource intensive but there is an easier way that is better, faster and cheaper.
The Prudential Regulatory Authority’s Supervisory Statement SS3/18 concerning model risk management principles is the latest in a long line of financial industry guidance that started with OCC 2011-12, The Federal Reserve’s SR 11-7 and others. Although it is highly focused on the models used for determining capital adequacy (stress testing) in UK banks, and the principles are sound, it is not good news for model risk managers.