Principle 2: Model Governance – Strengthening Model Risk Management for UK Banks in Alignment with SS1/23

Introduction

Models play a crucial role in supporting decision-making processes within banks. However, with the increasing complexity and interconnectedness of financial systems, it is essential for banks to have effective model risk management (MRM) practices in place. Principle 2 of the Bank of England’s Prudential Regulation Authority (PRA) Supervisory Statement (SS) 1/23 focuses on model governance. This blog post aims to provide an informative overview of Principle 2, its significance for banks in the United Kingdom and its dependencies, and the expectations placed on financial institutions to comply with this principle.

Understanding Model Governance

Model governance refers to the overall framework and processes put in place by banks to manage and oversee models effectively. It encompasses the allocation of responsibilities, decision-making structures, and controls related to model development, implementation, and ongoing use. Robust model governance ensures accountability, transparency, and proper oversight of models within an organization.

Importance for Banks in the United Kingdom

Model governance is of paramount importance for banks in the United Kingdom due to several reasons:

1. Regulatory Compliance: Compliance with the PRA’s expectations, including Principle 2, is a requirement for regulated UK-incorporated banks, building societies, and PRA-designated investment firms. Banks must adhere to these principles to demonstrate their commitment to strong risk management practices.
2. Enhanced Risk Management: Effective model governance supports comprehensive risk management. By clearly defining roles, responsibilities, and decision-making processes, banks can ensure that models are used appropriately and within acceptable risk limits.
3. Strengthened Oversight and Control: Model governance promotes robust oversight and control mechanisms. It establishes clear accountability for the overall MRM framework, ensuring that responsibilities are assigned to the most appropriate Senior Management Function (SMF) holder(s).

Expectations for Compliance

To comply with Principle 2 and establish effective model governance, financial institutions are expected to undertake the following actions:

1. Allocation of Responsibilities: Banks should clearly define and allocate responsibilities for model governance, including the identification of individuals or committees responsible for overseeing model risk management activities. These roles should be assigned to the most suitable individuals with the necessary expertise and authority.
2. Governance Framework: Establishing a governance framework involves developing policies, procedures, and controls that govern the entire lifecycle of models. This framework should address key areas such as model development, implementation, ongoing monitoring, and retirement.
3. Decision-Making Structures: Banks must have well-defined decision-making structures to ensure that model-related decisions are made by qualified individuals or committees. These structures should consider the complexity and potential impact of models on the bank’s operations.
4. Documentation and Communication: Clear documentation of model governance policies and procedures is crucial. Banks should maintain comprehensive records of model-related decisions, actions, and approvals. Effective communication channels should also be established to ensure that relevant information is shared across the organization.
5. Independent Review and Validation: Model governance should incorporate independent review and validation processes. This ensures that models are subject to impartial assessment, including validation by individuals or teams separate from the model development process.

Benefits and Challenges

Compliance with Principle 2 offers several benefits to banks:

1. Effective Risk Oversight: Robust model governance enables banks to monitor and manage model-related risks effectively. It ensures that models are developed and used within established risk tolerances and regulatory guidelines.
2. Accountability and Transparency: Clearly defined roles and responsibilities promote accountability and transparency. This allows for proper oversight, ensuring that decisions related to models are made by qualified individuals and documented appropriately.
3. Regulatory Confidence: Adherence to model governance principles enhances regulatory confidence in banks’ risk management practices. Compliance with the PRA’s expectations demonstrates a commitment to maintaining strong controls and mitigating model-related risks.

However, implementing effective model governance may pose challenges:

1. Organizational Complexity: Banks with complex structures or operations may find it challenging to establish a unified model governance framework across the entire organization. Careful coordination and integration efforts are required to ensure consistency and effectiveness.
2. Resource Allocation: Implementing a robust model governance framework necessitates dedicated resources, including personnel, technology, and training. Banks must allocate sufficient resources to establish and maintain an effective governance structure.
3. Balancing Flexibility and Control: Model governance should strike a balance between providing flexibility for innovation and ensuring appropriate control and oversight. Banks must find the right equilibrium to support innovation while maintaining prudent risk management practices.

Conclusion

Principle 2 of the Bank of England’s SS1/23 highlights the significance of model governance for banks in the United Kingdom. By complying with this principle, financial institutions can establish effective frameworks to oversee and manage models, ensuring accountability, transparency, and proper risk oversight. Successful implementation of model governance enhances risk management practices, regulatory compliance, and confidence in the banking sector. While challenges may arise during the process, the benefits of aligning with Principle 2 far outweigh the obstacles, ultimately strengthening model risk management across the industry.

How We Can Help

Model Risk Management on Connected Risk is a robust platform that allows you to manage and meet all of the obligations set within SS1/23 from the PRA. If you’re looking to meet regulatory requirements and obligations, our solution is the standard for your financial institution. Get started today using the form below, or learn more on our SS1/23 information page.