Model Risk Management (MRM) at HSBC is structured as a global function, headed up by the Chief Model Risk Officer (CMRO). The MRM function reports directly to the Group Chief Risk and Compliance Officer (GCRCO) ensuring its independence from the model developing and owning areas of the firm.
MRM are the second line of defence (2LoD) for Model Risk and the CMRO is the global Model Risk Steward for the group and is also accountable for the global operation of the MRM function. MRM teams are based in each region, to ensure local subject matter expertise and to guide, review, and challenge. MRM activity is managed on a global basis as many models are used in multiple locations. This enables MRM to operate consistently and efficiently globally, and to take account of additional local regulatory requirements.
Model Risk Governance - Setting the firm's model risk policies and standards, ensuring that model risk is managed within the approved tolerance levels, providing second line assurance on the implementation of policy, and monitoring regulatory developments impacting model risk.
Model Risk Stewardship - Facilitating responsible development, understanding and use of models and analytics, as well as providing subject matter expertise, advice, guidance, and effective challenge across all entities, regions, global businesses, and functions.
Independent Model Validation- Independently reviewing and (re)validating models, providing an objective, unbiased and critical opinion on the suitability and soundness of models for their intended use and the accuracy, relevance and completeness of outputs used to inform business decisions.
Infrastructure - provides specialist technical expertise and are responsible for delivery of infrastructure and reporting capability used across all geographies, business, and functions to support the effective management of model risk.
Independent Model Validation is a specialist quantitative role within the Model Risk Management team responsible for carrying out independent validations of HSBC’s model landscape, in order to identify and communicate model limitations and issues.
Independent Model Validation provides independent challenge of a model’s underlying theoretical assumptions and limitations, its practical implementation, its live application and business usage, providing stakeholders (including model users, senior management, audit and regulators) with assurance that models and tools developed, maintained and used within HSBC Group are fit for their intended purposes and are compliant with applicable internal and supervisory expectations. They will also review remediation plans and activities, undertake portfolio level reviews across model types and challenge the model owners on the appropriate application of relevant policy of models.
Model types include but are not limited to Credit Risk models (Retail and Wholesale), IFRS9 models, Stress Testing and Scenario Analysis models, Economic Capital models, Financial Vulnerability models, Pricing models, Traded Risk models, Insurance Risk models and models covering non-financial areas e.g., transaction monitoring, customer selection and human resources. This includes the traditional model types as well as modern approaches such as machine learning (ML) and artificial intelligence (AI) techniques.
Undertake model validation activities as dictated by the Global Model Risk Policy including the assessment of; model inputs, calculations, reporting outputs, conceptual soundness of the underlying theory and the suitability of the use for its intended purpose, relevance and completeness of data, qualitative information and judgements, documentation, and implementation of the model.
