• Reviewing and testing credit risk, market risk, liquidity, and pricing models

• Providing clear and complete documentation of all model testing

• Engaging with model owners and model developers on all issues

• Developing independent models

Such models can be used to confirm, via independent implementation, that model specifications and ideas are correctly implemented. In some cases, if desired, challenger models can be built to confirm, after model performance analysis and cost benefit analysis, that the most efficacious models are deployed. Challenger models might incorporate methodologies described in recent literature.

• Implementing model risk management policies and procedures

• Developing model risk governance infrastructure