Large Bank Examination Workshop February 2026

H.

Reporting

Periodic updates will be provided to the Risk Committee and Model Risk Management Committee on the results of completed model validations and the resolution of recommendations. Model validation reports will be provided to the corporate officer to whom the model owner reports.

IV.

Administration:

A.

Roles and Responsibilities

(1) Owner: The VP/Director of Operational Risk Management. The owner will present this policy to the Model Risk Management Committee for review and request an approval recommendation to the Authorized Approver.

(2) Authorized Approver: The Risk Committee of the Board of Directors.

B.

Governance

(1) Re-Adoption Frequency: The policy will be presented to the Authorized Approver for re-adoption annually, whether or not any changes have been made.

(2) Review Frequency: The Owner is expected to review this policy annually and recommend revisions as appropriate.

C.

Exception Management/Policy Interpretations

(1) Approval of Exceptions: All exceptions under this policy must be approved by the Chief Risk Officer and reported to the Risk Committee of the Board of Directors.

(2) Responsibility for Interpretations: The VP/Director of Operational Risk Management is responsible for all interpretations of this policy.

V.

Compliance Monitoring:

The AVP/Manager of Model Risk Management is responsible for setting up and maintaining procedures designed to monitor compliance with this policy.

VI.

Applicable Laws and Regulations:

• 12 CFR Section XXX.X (Independent validation of Bank internal risk model or internal cash flow model)

• Federal Guidance XXX-XX-XXX (Model Risk Management Guidance)

8

Model Risk Management Policy

March 15, 20XX

Classification: Confidential

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