Overlay · not the system of recordHolds sit above scoreAsk Desk is deterministic — no modelLocal
GRC / regulatory analyst
OCC MRIA — model risk documentation
OCC 2011-12 / MRIA 2026-03
Hold · Exam / MRIA · cannot auto-clear
PriorityP1
Severitycritical
PacketReady
Suggested—
This is a hold, not a ticket. A human has to look. Desk will not auto-release it.
Why this is here
Exam team asked for challenger-model evidence on the deposit-pricing model. Packet is partial.
ExamMRIA dated 16 days ago
Model inventoryDP-17 last validated 2024-09
GapNo challenger results attached
Recommended. Stand up a response workspace. Pull last validation memo. Do not wait for a perfect pack.
The MRIA language is broader than deposit-pricing. Scope creep is the failure mode.
Current: Open
Overlay only. Will POST a label to the write-back URL, never a funds release. IBM OpenPages OPSS-Iss:WorkflowStatus=WATCH on reg-occ-mria. Desk is not the system of record.