Banks, credit unions and lenders

A deposit-taker makes consequential decisions by the thousand: who gets credit and on what terms, which transaction is flagged, whose account is restricted, how a complaint is answered. More of those decisions are made or shaped by models and software every year, and the supervisors have noticed.

Conditionary’s financial-services pack brings together the instruments that bind a lender: OSFI Guidelines E-23 (model risk), B-10 (third-party risk) and B-13 (technology and cyber risk) for federally regulated institutions; FSRA, BCFSA, the AMF, the Deposit Guarantee Corporation of Manitoba and Nova Scotia’s CUDIC for provincial credit unions and caisses; Regulation B adverse-action notices, the Fair Credit Reporting Act and the revised interagency model risk guidance (SR 26-2) in the United States; the PRA’s SS1/23 and the FCA’s Consumer Duty in the United Kingdom; and DORA in the European Union. General privacy and human rights law sits underneath all of it.

The set-up guide asks about your decisions in a banker’s words: credit adjudication, transaction fraud scoring, customer chat, recruiting. It proposes the controls a model risk function already has, and a person confirms them. Case checks then test the per-case rules, such as whether every adverse decision produced its notice on time.

Ready to run: The Evidence summary for an insurer and the OSFI E-23 model inventory layout come ready to run. See the reports.