What you will be responsible for
Supports the division senior leadership (EVP and SVPs) in ensuring that they and their teams are properly trained on the Model Risk Management (MRM) Framework and apply the principles as required. This aspect of the role includes creating/maintaining operating procedures to ensure all business team members are adequately trained in the Model Risk Management principles and requirements as appropriate for their role.
Establish and own the model and tool identification process within the business unit and sign off on business team’s model decisions for all tools:
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Serve as a Business Team Owner and provide oversight of GCF’s EUDT inventory
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Works with the business team’s Tool/Application Inventory to ensure it:
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includes all tools (EUDT, Third Party, IT applications)
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Includes the populated model decision tree, date of first use, version in use, and list of legal entities with permission to use model output.
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Includes related identifiers which identify the tool elements in other systems (Model Risk Governance (MRG) MRG, GMAS, TPRM, AIW, etc.)
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Reviews and approves all production changes for tools, to ensure tools are evaluated against the model determination decision tree at every material change.
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Ensures model determination is performed at the start of development of any new tool, before the tool goes into first use, and prior to use of any changes to the tool. Ensures that any tool designated as a model is validated and approved for use to deployment/use in compliance with MRM Policy.
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Reviews and approves the tiering decisions made by the business teams for new models, ensuring sufficient supporting information / justification are captured and the proposed tier is consistent with the MRM Tiering Framework
Establish and oversee the GCF governance framework for End User Developed Tools (EUDTs) and the responsible use of artificial intelligence within business-owned tools, processes, and solutions. Act as a liaison between GCF business teams and the applicable EUDT, Artificial Intelligence, Model Risk Management, Technology, Cybersecurity, Privacy, Legal, and Compliance governance functions.
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Establish and maintain an inventory and oversight process for GCF-sponsored AI use cases and AI-enabled solutions, including generative AI, copilots, prompts, agents, machine learning capabilities, and AI functionality incorporated into business processes or technology solutions.
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Ensure proposed AI use cases are appropriately identified, documented, risk assessed, and submitted through applicable enterprise AI governance and approval processes before implementation or production use.
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Evaluate whether tools and solutions may be subject to multiple governance frameworks, including EUDT, AI, model risk, data, privacy, cybersecurity, third-party risk, and technology-development requirements, and coordinate the required reviews with the applicable subject-matter experts.
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Promote the responsible use of AI by ensuring that approved tools are used only for authorized purposes and that AI-assisted outputs receive human review, validation, and challenge appropriate to the use case and potential business impact.
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Monitor changes in EUDT and AI-related policies, standards, regulatory expectations, and enterprise guidance; assess their impact on GCF; and translate new requirements into sustainable business procedures, controls, training, and management reporting.
Annual Inventory Certification
Supports the GCF leadership’s Annual Inventory Certification Process:
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Work with business to execute annual Inventory Certification in accordance with operating procedures and provide MRM with evidence to ensure the completeness and accuracy of model inventory and associated model attributes as required by MRM in the MRG system (e.g., model stakeholders, model inventory, organization, materiality, use, proposed tier, validation status, implementation details, model changes, compensating controls, model developer / team, legal entity use, model users, and other attributes relayed in the SVP Dashboard.
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Supports the business through the annual Inventory Certification process, including attesting on an annual basis that appropriate business procedures and controls are in place which satisfy MRM guidelines and that any model newly identified during the Inventory Certification Process has been reported to MRM.
Model Development, Documentation, and Implementation
Ensures that all model owners adhere to the proper requirements for development, documentation, and implementation of all models in a manner consistent with the MRM Model Development Requirements and submission requirements. Educate or facilitate the education of model developers/implementers as to the MRM requirements.
Ensures that all models are communicated to MRM and validated/approved with conditions by MRM prior to use, that the use of model output is restricted to approved uses, that compensating controls, if required, are correctly applied and maintained, that all uses and users are tracked, and that any new potential uses are documented and communicated to MRM prior to use via the model change request workflow.
Ensures that Model Owners communicate changes in validation status, model use approvals/restrictions and the use of compensating controls to appropriate parties, including Sr. Leadership and Model Users.
Ensures that all model overlays are subject to an internal review process with management signoff to ensure overlay requests follow the MRM Guidelines and that a member of MRM is present at overlay committee approval meetings.
Ensures that all model ongoing monitoring submissions are subject to internal review process with management signoff to ensure the model complies with MRM Model Ongoing Monitoring Requirements including review of relevant documentation and execution procedures.
Ensures that overlay usage is pre-approved, remains compliant to terms of the approval, and is documented in the Model Risk Governance (MRG) Platform.
Responsible for approving all production changes for models, to ensure MRM approval is in place and MRM Inventory is updated to reflect such changes.
Ensures that all changes to models are properly tracked (with version numbers), documentation updated (with version number) and changes communicated to MRM prior to use via the model change request workflow. Ensures that the model tier is re-evaluated annually, and at each material change, to ensure alignment with the MRM Tiering Framework.
Facilitated the model validation process as needed between model developers and validation teams. Follow through as needed to ensure appropriate remediation steps, if identified, are implemented.
As part of the inventory management, ensures that activity status changes, such as retirements, are relayed to MRM in advance, and that model determination exercise is performed for replacement tools to ensure any replacement tools identified as models are relayed to MRM and validated prior to use.
Act as a delegate/Proxy for the Head of Global Credit Finance or Head of Business Intelligence and Strategy as needed at the State Street Model Risk Committee.