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The pace of regulatory
change is accelerating.
MBS can help you stay on track.
FDIC / OCC / CFPB
Regulatory compliance is more than playing defense….
MBS can help you assess your compliance readiness, identify regulatory KPIs and reduce your regulatory risk.
Third-Party Management Rules
Mortgage Servicing Rules
Hedge Model Validation
Every mortgage lender must comply with the QWR / CFPB Servicing Rules and the Vendor Management Rules.
Understanding the purpose of Regulatory Requirments offers an opportunity to strengthen your organization by implementing key performance indicators for each regulatory objective.
Hedge Model Validation
Hedging is an essential strategy for any mortgage lending operation to achieve maximum profitability to preserve a competitive market position.
There are inherent risks in any computer model that must be assessed to ensure the model recommendations are sound and provide the expected value preservation result.
Watch a VIDEO about Hedge Model Validation.
Read the OCC Bulletin 2011-12 (FRB SR 11-7) on Risk Model Validation.
Learn more about Secondary Marketing support on the MBS Webpage.
The FRB, OCC & FDIC requires validation of computer risk models
The basis for the validation is described as follows
Computer models are conceptual depictions of the various relationships between events and values in the real world, and are used by banking institutions to estimate risk, analyze business strategies, and estimate values of financial instruments and acquisitions. However, even the most complex of these models are still only approximations of real events and require the use of certain generalizations, making model development an extremely complex process. If proper attention is not paid during model development, the most minor of irregularities can lead to major errors in a model’s predictions and recommendations. Furthermore, given that the internal logic of most models is usually very abstract and somewhat limited, it requires considerable business judgment and proficiency to apply model results correctly.
Thus, it is critical that any model used by an organization be properly validated to ensure that these judgments are made using the most accurate information possible. This model validation not only increases the reliability of a model but also promotes improvements and a better understanding of its strengths and weaknesses among both model users and bank management.
The best way to avoid computer model risk is to implement a sound model validation structure that includes a strong validation policy and appropriate independent review. To properly establish the validity of any model, it is important to review the three basic components of the model: the information input component, which includes the assumptions and data put into the model; the processing component, which includes the theoretical model that transforms the information inputs into estimates using often complex computer programs; and the reporting component, which translates the estimates calculated by the computer code into practical business information. Errors in any of these three components might cause the model’s output information to be worthless or deceptive. Therefore, it is necessary to examine all three of these model components before concluding the validity of a model.
In order to adequately assess these model components, there are three general procedures that need to be used. First, an independent review of the logical and conceptual soundness of the model is needed. Second, a comparison must be made of the model against a similar “benchmark” model yielding like results. Finally, a comparison of the model’s predictions against actual real-world events is required to verify its accuracy.
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