Agencies Revise Interagency Model Risk Management Guidance, Rescind Prior FILs
Summary
The FDIC, OCC, and Federal Reserve issued revised interagency model risk management guidance on April 17, 2026, replacing prior guidance (FIL-22-2017 and FIL-27-2021). The guidance establishes a risk-based approach to model risk management tailored to a banking organization's model risk profile, size, and operational complexity. The document explicitly does not create enforceable standards—non-compliance alone will not result in supervisory criticism.
What changed
The agencies revised model risk management guidance to address growing complexity and scope of model use in banking and financial services. Key changes include a risk-based approach to model risk management tailored to each organization's profile and a clarification that the guidance does not set enforceable standards or prescriptive requirements, meaning non-compliance alone will not result in supervisory criticism. The document rescinds two prior FDIC guidance documents (FIL-22-2017 and FIL-27-2021).\n\nAffected banking organizations, particularly those with over $30 billion in total assets, should review the revised guidance to understand updated supervisory expectations for model risk governance, validation, and monitoring. Banks with $30 billion or less in assets are generally outside the scope unless they have significant model risk exposure. Compliance teams should assess whether existing model risk management practices align with the revised guidance principles.
Archived snapshot
Apr 19, 2026GovPing captured this document from the original source. If the source has since changed or been removed, this is the text as it existed at that time.
Agencies Revise the Interagency Model Risk Management Guidance
Supervisory Guidance April 17, 2026
Summary:
On April 17, 2026, the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, and the Board of Governors of the Federal Reserve System issued revised model risk management guidance and rescinded existing model risk management guidance.
Statement of Applicability: The contents of, and material referenced in, this FIL apply to all FDIC-supervised financial institutions. The guidance is expected to be most relevant to banking organizations with over $30 billion in total assets.
Highlights:
- Use of models within the banking and financial services industries continues to grow in complexity and scope. Advances in technology along with increased competition have driven banking organizations to leverage innovative approaches to improve efficiencies, better mitigate risks, and help maximize profits.
- The FDIC is issuing this revised model risk management guidance to clarify model risk management principles, and to set forth a risk-based approach to model risk management, tailored to a banking organization’s model risk profile and the size and complexity of its operations.
- The guidance generally does not apply to models used by banking organizations with total assets of $30 billion or less, to the extent such institutions do not have significant exposure to model risk. Such models are typically subject to internal risk management and governance practices appropriate for the size and risk profile of these banking organizations.
- This guidance does not set forth enforceable standards or prescriptive requirements; accordingly, non-compliance with this guidance alone will not result in supervisory criticism against a banking organization.
- With the issuance of this revised guidance, the FDIC is rescinding existing model risk management guidance (FIL-22-2017 and FIL-27-2021). FIL-15-2026 ## Attachment(s)
Model Risk Management - Revised Guidance
Related Topics
Corporate Governance and Auditing Programs Third-Party Relationships
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Division of Risk Management Supervision
Last Updated: April 17, 2026
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