Model-Risk
- Reconciled to What? The Denominator Nobody Reports
Supervisors on three continents expect regulatory returns to be reconciled and validated. Not one expects the number to say what it was computed over — and that denominator is where reporting systems actually fail.
- Four Comments on OSFI's Draft ILAAP Guideline
Four comments on OSFI's draft ILAAP guideline, all on Section 3.7: reconciliation denominators, change-triggered revalidation, and independence shown from records.
- Six Regulators, One Requirement: Separate Development From Review
Canada, the UK, Switzerland, the US, the euro area and the EU all require model development and review to be separate. One supervisor says it is often missing.