Alex Li

Regulatory Gap: Why Model Risk Management Is Structurally Ill-Suited to Govern AI-Driven Code Transformation

Model Risk Management (MRM), set out in the Federal Reserve's SR 11-7 and OCC Bulletin 2011-12, governs quantitative models in banking. AI vendors now offer tools for rewriting production code, including COBOL-to-Java modernization, raising a scope question for the estimation-ori...