Strategic Briefing
April 2026
The revised interagency model risk management guidance introduces a more tailored framework for banking organizations. While SR 26-2 is expected to be most relevant to institutions over $30 billion in total assets, community and regional banks below that threshold should not treat the guidance as irrelevant.
This briefing explains how banks under $30 billion should read the new guidance, including the importance of the carve-in language for institutions with significant model risk, fintech partnerships, AI/ML tools, digital asset exposure, or activities outside traditional community banking norms.
What the Briefing Covers
The briefing provides a practical decision framework for sub-$30 billion institutions, distinguishing between banks with reduced MRM expectations, banks partially in scope due to one or more carve-in factors, and banks that should continue applying a more complete SR 26-2 model risk framework.
It also explains why model risk management remains important even where supervisory expectations are lighter. Vendor models, AI tools, credit models, BSA/AML systems, and digital channels can still create material risk regardless of asset size.
Key Topics
- The April 17, 2026 bulletin in context
- How to interpret the $30 billion threshold
- Carve-in conditions for smaller institutions
- Three-path decision framework for sub-$30B banks
- AI, vendor model, and digital asset governance considerations
- What right-sized model risk management looks like
Access the Full Briefing
View the full briefing for the complete analysis, decision framework, and recommended model risk management approach for community and regional banks.