In April 2026, the Federal Reserve, OCC, and FDIC issued revised, risk-based model-risk guidance that supersedes SR 11-7 and SR 21-8. It is expected to be most relevant to banking organizations with more than $30 billion in total assets, but may also be relevant to smaller organizations with significant model-risk exposure.
The guidance excludes generative and agentic AI models from its scope while directing banks to use their own risk-management and governance practices for systems outside it. Its principles continue to apply to traditional statistical and quantitative models and non-generative, non-agentic AI models. Separate interagency guidance says using a third party does not diminish a bank's responsibility to operate in a safe and sound manner and comply with applicable laws and regulations.
The ARC rules in this workflow are deterministic, not predictive.
SR 26-2 excludes deterministic rule-based processes from its model definition when no statistical, economic, or financial theory underpins their design or use. The bank determines the classification and controls for its deployment.
Compass does not interpret the rules or accept risk for the bank. It preserves the evidence and accountable decision behind each use case.