Regulation — banking-specific
FDIC FIL-22-2017 — SR 11-7 adopted for FDIC-supervised institutions
The FIL that pulled SR 11-7 into the FDIC exam handbook. Community banks, state-chartered banks, and thrifts that thought "SR 11-7 is a Fed thing" learned in 2017 that it now applies to them — with FDIC exam teams enforcing the same model-risk-management discipline.
What the FIL actually says
"The FDIC is adopting the Interagency Supervisory Guidance on Model Risk Management, previously issued as Federal Reserve SR 11-7 and OCC Bulletin 2011-12, for FDIC-supervised institutions. The guidance applies to state nonmember banks and state savings associations. Institutions should consider the guidance and its applicability to their model use as part of their overall risk management framework."
FDIC FIL-22-2017 — adoption statement (paraphrased summary)
"The extent and rigor of model risk management activities should be commensurate with the extent to which the institution uses models, the complexity and materiality of its models, and the size and complexity of the institution's operations."
FDIC FIL-22-2017 — proportionality principle
What this means in plain English
Two things every FDIC-supervised bank running an AI credit-underwriting model needs to know:
- SR 11-7 applies to you. Not "consider" as optional — consider as the exam-team stance. State-chartered + community + savings-association charter does not opt you out.
- Rigor scales. A community bank with one AI credit model is not held to the same volume of documentation as a top-10 institution — but the underlying discipline (independent challenge, ongoing monitoring, governance) is the same.
The "we're too small for SR 11-7" answer stopped working in 2017.
What triggers the exposure in the sample
Silent drift + no independent-verifier record on file at the FDIC exam entry-meeting. FDIC exam teams working from the FIL-22-2017 stance will ask: "show us your model-risk-management framework applied to the AI credit-underwriting engine, and show us the independent-challenge record." A vendor screenshot is not the answer they are trained to accept.
What the $499 Snapshot shows against this rule
- Independent-verifier record — proportional to a mid-market bank, not a G-SIB documentation load
- Named AI surface + dated determination + retained evidence — the FIL-22-2017 core deliverables in one file
- 3 fix-first items scaled to community / mid-market operational reality — not a top-10-bank retrofit plan
- Signed declaration by a named principal — the exam team's cross-examinable record
Read the independent-verifier declaration →
$499 Snapshot. 3 business days.
The proportional independent-verifier record FDIC exam teams are trained to look for.
Buy $499
Snapshot credit applies to Baseline ($2,500) or Enterprise Attestation ($35-55K) upgrade within 30 days.