Solution · Model risk management
11

Validator independence, enforced rather than asserted.

An SR 26-2 shaped model inventory derives each model’s tier, schedules validation from it, and requires a validator distinct from the developer at sign-off.

ForModel & AI governance
SurfacesModel risk · AI systems · Validation · Findings
The shape of the problem · 01

What this actually feels like.

  • 01The model inventory is a spreadsheet, and each tier is whatever someone typed in.
  • 02Validation dates live in a calendar reminder that nobody owns.
  • 03Effective challenge is asserted in a memo, and nobody can show who validated what.
  • 04AI features turn up inside vendor products before anyone has registered them.
How Zovos handles it · 02

Five steps, one graph.

Every step writes back to the same controls, policies, and issues your team already owns. There is no second source of truth.

  1. 01
    Inventory
    Register each model in the inventory, with SR 26-2 lineage from development through use captured on the model workpaper.
  2. 02
    Tier
    A risk scorer derives the tier from the model’s attributes, so nobody enters it by hand. The tier drives validation cadence and oversight.
  3. 03
    Validate
    Validation is scheduled from the tier, and sign-off requires a validator distinct from the model’s developer.
  4. 04
    Review bias
    Record bias and fair-lending reviews against the model, with the methodology and the results your partner produced, so the fairness evidence stays with the governance record.
  5. 05
    Register AI
    The AI systems registry inventories AI use cases, including AI inside software you bought, with risk tiering and a maker-checker go-live gate. AI governance maps to the NIST AI RMF and ISO/IEC 42001.
What changes · 03

What the product does instead.

Tiering
The tier is derived by a scorer rather than entered as a label.
Independence
Validation sign-off requires a validator distinct from the developer.
Guidance
Built to SR 26-2 / OCC 2026-13, the successor to SR 11-7.
AI coverage
AI systems are registered and tiered alongside models and mapped to the NIST AI RMF and ISO/IEC 42001.

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