Artificial intelligence (AI) and machine learning (ML) models have become indispensable tools in modern business, offering the potential to solve complex problems and drive innovation. However, the risks associated with these models can be difficult to identify, posing significant challenges for organizations. Enhancing model risk management (MRM) is essential for firms to effectively leverage the power of AI/ML while ensuring responsible innovation and stakeholder trust.
The Importance of Model Risk Management in AI/ML
Sound risk management of AI and ML models is crucial for fostering responsible innovation. This process requires an effective governance framework from the inception of the AI/ML model and throughout its entire lifecycle to properly cover and mitigate risks. Responsible innovation not only enhances stakeholder trust but also ensures that AI/ML technologies are used ethically and effectively.
Four-Step Process for Effective AI/ML Adoption
To accelerate the adoption of AI/ML and create stakeholder trust, a robust governance and risk management framework is essential. This process involves four key steps:
- Developing an Enterprise-Wide AI/ML Model Definition: Identifying AI/ML risks begins with a clear and comprehensive definition of what constitutes an AI/ML model within the organization. This definition helps in recognizing and addressing potential risks associated with these models.
- Enhancing Existing Risk Management and Control Frameworks: Existing risk management and control frameworks must be updated to address AI/ML-specific risks. This includes incorporating new strategies and tools to manage the unique challenges posed by AI/ML models.
- Implementing an Operating Model for Responsible AI/ML Adoption: Establishing an operating model ensures that AI/ML adoption is conducted responsibly. This includes setting up proper governance structures, accountability mechanisms, and ethical guidelines for AI/ML use.
- Investing in Capabilities Supporting AI/ML Adoption and Risk Management: Organizations need to invest in the necessary capabilities, such as data governance, infrastructure, and skilled personnel, to support AI/ML adoption and manage associated risks effectively.
Enhancing Trust Through Effective MRM
Effective MRM plays a critical role in embedding supervisory expectations throughout the AI/ML lifecycle. This approach helps anticipate risks and reduces potential harm to customers and other stakeholders. Model owners and developers are held accountable for deploying models that are conceptually sound, thoroughly tested, well-controlled, and appropriate for their intended use.
Regulatory Perspective
Regulatory agencies, particularly in the US banking sector, are closely monitoring AI/ML developments. Regulators aim to balance the benefits of innovation with the associated risks, as seen in recent guidance regarding the use of alternative data in consumer credit. Financial services firms can leverage existing MRM processes—such as risk assessment, validation, and ongoing monitoring—to address AI/ML-specific risks and align with regulatory expectations.
However, four aspects of AI/ML require additional investment:
- Diverse Use Cases: AI/ML applications are expanding into areas like document intelligence and advertising, necessitating more comprehensive risk management strategies.
- High-Dimensional Data and Feature Engineering: The reliance on complex data and advanced feature engineering can introduce new risks that need to be managed.
- Model Opacity: The “black box” nature of some AI/ML models makes it difficult to understand their decision-making processes, increasing the need for transparency and interpretability.
- Dynamic Training: AI/ML models often require continuous retraining with new data, which can lead to unexpected results if not properly managed.
Unique Features and Risks of AI/ML Models
Like traditional models, AI/ML models can lead to adverse consequences if there are errors in their design, poor performance, or inappropriate use. However, the complexity of AI/ML models introduces unique challenges. High-dimensional data, dynamic retraining, and opaque transformation logic can result in unexpected outcomes, making risks harder to identify and assess.
Common Risks in AI/ML Models
- Implementation Errors: Errors in calibration and poor data quality can affect model performance.
- Overfitting and Underfitting: Overfitting occurs when a model fits the training data too well, leading to poor prediction performance on new data. Underfitting happens when a model fails to capture the data adequately, resulting in poor performance even on training data.
- Inappropriate Use: AI/ML models can produce unintended consequences if used inappropriately. It’s essential to ensure that the model’s results are relevant and informative for achieving the desired business outcomes.
Governance, Policies, and Controls
Effective oversight of AI/ML models should mirror the processes used for traditional models. Board and senior management should be aware of AI/ML use cases and the effectiveness of governance and controls throughout the model lifecycle. Clearly defined roles and responsibilities for model developers, users, validators, and other control functions are vital for ensuring ownership and accountability for risks.
MRM policies should explicitly reference how other risk and control requirements, such as information security, apply to AI/ML models. This clarity helps model developers understand the requirements needed for model approval and ensures control functions know their responsibilities. Additionally, documenting procedures related to enhanced capabilities and their relationships to other policies is crucial.
Conclusion
The risks of AI/ML models can be challenging to identify, but with effective MRM, organizations can leverage these powerful technologies responsibly. By developing a comprehensive governance framework, enhancing existing risk management practices, and investing in the necessary capabilities, firms can foster stakeholder trust and ensure ethical AI/ML adoption. This proactive approach not only mitigates risks but also paves the way for innovative solutions to complex problems.
