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OCC 2011-12

OCC Bulletin 2011-12: Sound Practices for Model Risk Management

OCC Bulletin 2011-12, 'Supervisory Guidance on Model Risk Management,' articulated the elements of a sound program for managing risk from quantitative models used in bank decision-making. Its text was substantively identical to the Federal Reserve's SR 11-7, reflecting that both agencies developed the guidance jointly, and it applied to national banks and federal savings associations supervised by the OCC.

Published: Last updated: Last reviewed by: Model Risk Directory editorial team
Quick answer

OCC Bulletin 2011-12 was the OCC's companion issuance to the Federal Reserve's SR 11-7, published the same day in April 2011, applying identical model risk management expectations to OCC-supervised national banks and federal savings associations. It was rescinded April 17, 2026 and replaced by OCC Bulletin 2026-13, issued jointly with the Fed and FDIC.

Jurisdiction
United States
MRM relevance
Direct model risk management guidance
Effective date
Rescinded 17 April 2026
Issuing body
Office of the Comptroller of the Currency
Official reference
www.occ.treas.gov/news-issuances/bulletins/2011/bulletin-201

What it covers

  • Sound practices for model development, implementation, and use
  • Independent model validation as a distinct, resourced function separate from model development
  • Governance, policies, and controls, including board and senior management oversight of the model risk program
  • Model risk scales with model complexity, uncertainty about inputs, scope of use, and potential impact
  • Applied specifically to OCC-supervised national banks and federal savings associations

Adoption status

The OCC rescinded Bulletin 2011-12 on April 17, 2026, alongside the Federal Reserve's rescission of SR 11-7, replacing it with Bulletin 2026-13, 'Model Risk Management: Revised Guidance.' The 2026 guidance explicitly states it does not set forth enforceable standards or prescriptive requirements, and non-compliance alone will not result in supervisory criticism, a notable shift toward a risk-based, tailored posture. It is expected to be most relevant to institutions with over $30 billion in total assets, though smaller OCC-supervised banks with meaningful model risk exposure may still find it relevant.

Reference only. This page explains what OCC 2011-12 covers; it is not a claim that Model Risk Directory or any listed vendor satisfies it. Verify alignment directly against the issuing body's own current text before relying on it.

Sources. source 1 · source 2 · source 3. Data as of 2026-07. See methodology.

Related content

GuideOCC Model Risk ManagementOCC-supervised national banks and federal savings associations are now governed by OCC Bulletin 2026-13, 'Model Risk Management: Revised Guidance,' issued jointly with the Federal Reserve and FDIC on April 17, 2026. It replaced the long-standing OCC Bulletin 2011-12, shifting to a risk-based approach while keeping the same foundational model development, validation, and governance disciplines.GuideSR 11-7 ComplianceSR 11-7 was formally rescinded on April 17, 2026 and replaced by the interagency guidance SR 26-2. Institutions still describing their program as 'SR 11-7 compliant' should update to reference SR 26-2, which preserves SR 11-7's core disciplines, effective challenge, independent validation, governance, while shifting to a risk-based, tailored supervisory approach.GuideModel Risk Management FrameworkA model risk management framework is the documented set of policies, roles, and processes an institution uses to identify, tier, govern, and validate its models. Under SR 26-2, a sound framework covers model development and use, independent validation, and governance and controls, scaled to the institution's size and model risk profile rather than applied uniformly.InsightThe global map of model risk management frameworksThere is no single global MRM rulebook. This map separates enterprise model risk guidance from model-specific and adjacent controls so banks, insurers, and procurement teams can identify the right source before scoping validation work.