Model risk management federally regulated financial institutions
The map is the record.
OSFI’s Guideline E-23 binds on 1 May 2027. Draw the model inventory as one map, and every door, every decision and every hash sits on the record beneath it.
- 01The registerEvery model, every door open or shut, and why.
- 02Rules that refuseA move waits for a second person; the hands that built a model cannot approve it.
- 03A record you can checkEvery row carries its hash, and sha256sum recomputes it.
What E-23 asks an institution to demonstrate
Financial institutions rely on models to make, support and inform important decisions — credit, fraud, AML, capital, pricing, underwriting, forecasting and, increasingly, AI-enabled applications. The challenge is not having models. It is knowing, at an enterprise level:
- What models exist, and where are they being used?
- Which models are material or high risk?
- Who owns each model, who developed it, who independently validated it, and who approved it?
- What are its dependencies and limitations?
- When was it last reviewed, and is it being monitored?
- Has anything materially changed since?
- What evidence exists to demonstrate that the governance process actually happened?
Knowing is not the same as proving. MINERVA is the model governance system of record — a control room for an institution’s models and AI governance — where each answer is one structured record and the evidence is produced from it, not assembled after the question.
The 30-day readiness pilot
One institution. Its real inventory. The gap report and the first board pack. No production data.