Generative and Agentic AI Fall Outside New Bank Model-Risk Guidance
New federal bank model-risk guidance excludes generative and agentic AI from scope, but points governance back to banks’ own risk controls.
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TL;DR:
Federal banking regulators revised model risk management guidance on April 17, 2026, replacing SR 11-7 and SR 21-8. The revised guidance excludes generative and agentic AI models from its scope, while directing banks to use their own risk management and governance practices for tools, processes, or systems not covered by the document.
Federal banking regulators revised model risk management guidance on April 17, 2026, replacing SR 11-7 and SR 21-8. The revised guidance excludes generative and agentic AI models from its scope, while directing banks to use their own risk management and governance practices for tools, processes, or systems not covered by the document.
What you need to know
- The change: Revised interagency model risk guidance replaces SR 11-7 and SR 21-8, and excludes generative and agentic AI from this guidance. (Federal Reserve)
- Who is most affected: The guidance is expected to be most relevant to banking organizations with over $30 billion in total assets, while smaller institutions may still need to consider it if they have significant model-risk exposure.
- Why it matters: The revised guidance separates covered model categories from generative and agentic AI models.
- What to do first: Start by separating the question “Is this covered by the revised model-risk guidance?” from the question “What governance and controls apply?”
- Key date or trigger: April 17, 2026.
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