Sector

Banking & capital markets

Where model risk management meets systems that act.

Federal Reserve SR 11-7 / OCC 2011-12
Internal audit & effective challenge
Operational resilience

The problem in one sentence

SR 11-7 was written in 2011 for models that score and predict. Your agents act. The guidance did not change — the exposure did.

Failure point	What actually happens
Inventory	Is an agent a model, an application, or forty models in a trench coat? Most MRM inventories cannot represent a system that chains tools, prompts and sub-models at runtime.
Validation	You validated the model. Did you validate the agent's authority? A well-scored model wrapped in an agent that can act outside its grant is a governance failure with excellent metrics.
Effective challenge	Challenge assumes the reviewer can reconstruct the decision. If the agent's context is gone, so is the evidence.
Monitoring	Model performance drifts slowly. Agent behaviour changes the day a provider ships a new version — with no code change and often no revalidation trigger.

Next step

The fastest route is a conversation. Bring the architecture you are worried about — the first useful thing usually surfaces inside twenty minutes.