Large Bank Examination Workshop February 2026

• Responsible for fully documenting and justifying model inputs, assumptions, theory, calculations, output, operation / use, controls and related procedures • Support the informational needs of the Model Risk Management Group • Responsible for providing a written response to model validation reports, indicating agreement or disagreement with findings and recommendations and specifying a timeframe for resolution • Responsible for ensuring changes to models and modeling processes are appropriately controlled and documented • Responsible for evaluating model output (e.g., risk metrics), inputs (e.g., data inputs and assumptions), and any manipulation of the output that goes into final reports • Responsible for ensuring models have been appropriately developed and implemented and are used for their intended purpose • Periodically review and, as appropriate, revise the Model Summary for each model • Oversee the procurement or development of new models or material changes to existing models • Perform periodic back-testing and benchmarking, as appropriate and if feasible • Request and review a model vendor’s available information regarding modeling assumptions and data sources, as applicable Model Users • Responsible for owning and using correct input data and fully understanding how the data was developed and its proper application in the model • Employ a model for its intended purpose and obtain necessary approval for using a model for other purposes • Participate in user acceptance tests of new model implementations and model changes • Raise model performance issues and initiate change requests when needed • Ensure models remain current and outstanding validation, examination and audit findings are addressed in a timely manner • Vet any on-top model adjustments with the model owner and the Model Risk Management Group Information Security • Provides services and guidance to ensure that the operating environment for the Bank’s models is secure`` Internal Audit • Provide audit-related findings to applicable model owners and the AVP / Manager, of Model Risk Management Senior SOX Compliance Analyst • Coordinates the internal control practices associated with the inventory of SOX Critical models Bank Technology • Ensures a stable model technology operating environment

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Model Risk Management Policy

March 15, 20XX

Classification: Confidential

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