SR 11-7 vs. SR 26-2: The Evolution of Model Risk Management from Validation Compliance to Risk-Based Governance
May 8, 2026
1. Executive Summary After more than a decade of operating under SR 11-7, U.S. banking regulators have introduced SR 26-2, fundamentally reshaping the supervisory philosophy surrounding Model Risk Management (MRM). While many initially viewed the new guidance as a routine modernization exercise, SR 26-2 represents a much broader shift in regulatory thinking — one that … More SR 11-7 vs. SR 26-2: The Evolution of Model Risk Management from Validation Compliance to Risk-Based Governance
