CMS Sept 2022

Internal Use Only

Independent Review Standalone market risk and model risk functions are relatively uncommon in the community bank space, consequently independent review falls to staff which is often enhanced with consultants.

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Internal Use Only

Independent Review Regulatory Guidance details 5 requirements for an independent review: 1. The adequacy of, and personnel’s compliance with, the bank’s internal control system 2. The appropriateness of the bank’s risk measurement system given the nature, scope and complexity of its activities 3. The accuracy and completeness of the data inputs into the bank’s risk measurement system 4. The reasonableness and validity of scenarios used in the risk measurement system 5. The validity of the risk measurement calculations. (actual vs forecasted results)

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