Upon Further Analysis — Archives

  • In Search of … Material Financial Risk

    Banking regulators claim that they are not loosening regulation and supervision but rather shifting the focus from box-checking processes to “material financial risk.” They have been largely successful in promoting this narrative. But does this view stand up to scrutiny? Can they even define material financial risk? Defining Material Financial Risk – Or Not On…

  • Travel: Some Guiding Principles

    Whether for business or pleasure, travel remains a big part of our lives. The world is replete with guidebooks, videos, influencers, and even AI-generated itineraries. You can find tips on tourist traps and hidden gems elsewhere. But we should also consider how to approach travel. Here are some my own guiding principles when it comes…

  • New Guidance on Model Risk – What’s In and What’s Out

    Banking regulators recently revised guidance on model risk management (MRM), superseding earlier, more detailed guidance from 2011. What were the major changes? And what impact are these changes likely to have on bank supervision? Drawing upon my own experience, I’ll look at what’s in, what’s out, and the implication of these changes for both examiners…