Large Bank Examination Workshop February 2026

Model Inputs - Data • If an organization decides that the model provides useful information despite data problems, the organization’s policies should specify that audit, risk management, and modeling personnel are independently responsible for apprising senior management of the data problems. • This alerts decision makers both that the model results may not be completely reliable and that there may be a need to devote more resources to providing quality data.

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Mark to Market • Marking to market is the valuation of positions at readily available closing prices that are sourced independently. Examples of readily available closing prices include:  exchange prices  screen prices  quotes from independent brokers. • Institutions should mark positions to market prices where possible. • Addresses ASC 820 Fair Value Level I securities.

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