Financial Model Governance Review · SR 26-2 ready
You already have the models. Can you defend them?
A fixed-scope review of how your bank governs the models Finance runs every month: funds transfer pricing, profitability, cost allocation, RAROC and planning. We review what you have. We don’t sell you a rebuild.
Why now
On April 17, 2026, the Fed, OCC and FDIC replaced SR 11-7.
SR 26-2 is the first rewrite of US model risk guidance in fifteen years. Three changes land directly on the models Finance owns.
A narrower definition of “model”
Quantitative methods built on statistical, economic or financial theory are in. Simple arithmetic and deterministic rules are out. Your FTP curve and your allocation engine may now land on different sides of the line.
Effort follows exposure and purpose
Material models get the full treatment. Immaterial ones can be identified and monitored. Someone has to make that call for each model, and document why.
Models are judged together, not one by one
Shared assumptions and data create risk across models. In Finance, one FTP curve feeds profitability, pricing, incentives, RAROC and the budget.
SR 26-2 is most relevant to banks above $30B in total assets. Smaller banks are expected to keep governance proportional to their size and risk profile. Sources: Federal Reserve SR 26-2; OCC Bulletin 2026-13; FDIC FIL-15-2026.
The gap nobody covers
Validation looks at one model. Your decisions run on a chain.
Model validation teams review models one at a time, and usually start with credit and market risk. The finance chain sits between Treasury, FP&A and the business lines. Each owner governs a link, and nobody governs the chain.
What we review
Nine dimensions, each scored 1 to 5.
Inventory & classification
Which finance tools are models under SR 26-2, which are critical tools, and where is that written down?
Materiality & tiering
Is the effort on each model proportional to its exposure and purpose?
Ownership & challenge
Who owns each model, who challenges it, and is that clear across Finance, Treasury, Risk and IT?
Assumptions & documentation
Are FTP curves and premiums, cost drivers and capital rules written down, with their rationale?
Monitoring & outcomes
Does profitability reconcile to the ledger? Is FTP cost checked against actual funding cost?
Change control & traceability
Can you show who changed a rule, driver or version, when, and who approved it?
Dependencies & aggregate risk
Which decisions break if the FTP curve or a key driver is wrong?
Vendor models & customizations
Do you understand the vendor logic you run, and are your customizations documented?
Use within purpose
Are pricing, incentives and plans using the models for what they were built to do?
How we go deep · Sáasil™
Agentic AI for deep discovery. A principal signs every finding.
We run the review with Sáasil™, our agentic AI framework for management accounting, built on Claude. Agents read the rules, drivers and documentation behind your models so the discovery goes wider and deeper than interviews alone. The judgment stays human.
Read
Allocation rules, driver tables, FTP curves, model documentation and the spreadsheets around them.
Map
A first draft of the inventory, the model / critical tool classification and the dependency chain.
Flag
Undocumented assumptions, outputs that don’t reconcile, orphan drivers and changes with no approval trail.
Validate
The principal reviews every finding. Nothing reaches your report without a human decision behind it.
Agents work only on the materials you choose to share, within your data policies.
What you get
Seven deliverables. Yours to keep.
- 01Governance scorecard across nine dimensions
- 02Classified inventory of your finance models (model / critical tool / out of scope)
- 03Dependency map from the FTP curve to every decision it feeds
- 04Findings ranked by materiality
- 0590-day roadmap your team can run
- 06Handover kit: documentation templates and ownership matrix
- 07Executive session with the CFO
How it runs
Fixed scope. Four to six weeks.
Inventory & classify
List every finance model in scope and place each one against the SR 26-2 definition.
Review
Interviews with owners, a look inside the models and the reconciliations, scoring on nine dimensions.
Map & prioritize
Dependency map of the chain, findings ranked by materiality, 90-day roadmap.
Executive session
Results with the CFO and, if you choose, the CRO. Then the handover kit.
What this is, and what it isn’t.
It is
- A review from Finance’s side, by someone who has built these models for 30 years
- Focused on FTP, profitability, cost, RAROC and planning models
- Fixed scope, fixed deliverables, senior principal on every session
- Compatible with any platform: Oracle EPM, OFSAA, other EPM tools or spreadsheets
It isn’t
- An independent second-line validation of credit, market or statistical models
- A GRC platform implementation
- A sales step toward a rebuild. If you want help afterward, that is a separate engagement
Who it’s for
Finance leaders who own the numbers the board uses.
Insights · Model governance series
Read before you call.
Tell us which models you have. We’ll tell you if a review makes sense.
Tell me which models you run and the platform they sit on. I reply personally, and I’ll tell you in the first conversation whether a review makes sense.
Or start with the free self-assessment →This review is not an independent model validation and does not constitute regulatory or legal advice.