SR 26-2 Changed the Rules. Are You Ready?

For fifteen years, SR 11-7 served as the foundation of model risk management across the banking industry. It established the expectations for validating, documenting, and governing models used to support everything from credit decisions to capital planning. Over time, those principles became deeply embedded in how financial institutions approached model governance.
With the release of interagency guidance modernizing that framework, SR 26-2 (Federal Reserve), OCC Bulletin 2026-13 (OCC), and FIL 15-2026 (FDIC) each signal the same direction: proportional, risk-based governance that aligns oversight with the materiality and impact of each model. Rather than prescribing a one-size-fits-all approach, the updated guidance emphasizes proportional, risk-based governance that aligns oversight with the materiality and impact of each model. SR 26-2 acknowledges that generative and agentic AI are rapidly evolving technologies outside the formal scope of the guidance, while making clear that existing enterprise risk management expectations still apply.

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SR 26-2 Changed the Rules. Are You Ready?

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