Target Audience
General Counsel, Chief Risk Officer, Board of Directors
Effective Date
2026.04.17
Exclusion from Conventional MRM
On April 17, 2026, the Federal Reserve, the Office of the Comptroller of the Currency (OCC), and the FDIC jointly issued SR 26-2, superseding the conventional SR 11-7 framework for Model Risk Management regarding autonomous architecture.
Generative AI exclusion and structural requirements.
The mandate distinguishes Generative and Agentic AI systems from conventional statistical models, noting that state-space autonomy cannot be fully verified through probabilistic testing, Monte Carlo simulations, or statistical sampling.
The administrative record establishes that systems exhibiting unbounded generative capability require dependency graph lineage and deterministic constraint verification to align with baseline oversight requirements.
Regulatory Parity Matrix
The GCCAI provides a mathematically verified reference point. By grounding operations in Isabelle/HOL deductive proofs rather than probabilistic estimation, the architecture provides structural alignment across the following evidentiary frameworks.