CMS Sept 2022

Internal Use Only

What is the Second Line of Defense? Includes Model Risk Manager, their team & the Board or Management committee responsible for overseeing the MRM function

They are responsible for establishing MRM policies & practices

25

Internal Use Only

First Line of Defense

Model owners & business units

Responsible for implementing policies & practices

Must work with framework established

Ensure models are properly developed, implemented & used

26

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