KYE Learn™ · Frameworks

SR 11-7 for AI agents.

The Fed's 2011 model risk guidance is the most useful AI-agent governance framework that already exists in US banking — because it was already about decisions, not just predictions. Here's how it maps when the model can act.

Published 2026-05-19 · reviewed 2026-05-19 · ~6-min read

The four classic model risk categories — extended

SR 11-7 categoryWhat it meant (2011)What it means for agents (2026)
Methodology errorWrong math, wrong assumption setWrong tool selection, wrong prompt strategy, wrong RAG corpus
Implementation errorCode bug, data pipeline bugAdapter bug, system-prompt drift, schema mismatch
Use errorModel used outside its scopeAgent used beyond delegated authority — the canonical authority gap
Output errorBad answer accepted into a decisionBad answer + bad action — and the action has happened
Action error (new)n/aThe agent did the right thing for the wrong reason / wrong principal / wrong scope. Replay-Proof™ exists because of this category.

The three-line model

SR 11-7 §VI organises model risk governance into three lines of defence. For AI agents:

  • First line — the business unit owning the agent. Designs the workflow, runs it day-to-day, owns the authority bindings.
  • Second line — independent model risk management. Reviews methodology, validates outputs, monitors drift, owns the Assurance Card.
  • Third line — internal audit. Re-derives decisions from Replay-Proof™ evidence packs. Tests effective challenge.

Effective challenge — the §IV cornerstone — is impossible without reproducible decisions. For non-AI models you could re-run the regression. For agents you need the evidence pack + the spec + the signatures. That's what Replay-Proof™ is.

Documentation expectations

SR 11-7 §V demands documented inventory, ongoing monitoring, change management. For agents the document set extends to:

  • Authority lattice — what each agent may do, granted by whom, with what purpose, until when.
  • Guard set — the runtime constraints that the agent runs under.
  • Shadow-mode baseline — the known-good comparison metric before enforcement.
  • Action log — every action taken by the agent, signed, hash-linked.
  • Authority-gap report — periodic review of where the agent acted outside its authority and why.

How KYE Protocol™ maps

See the SR 11-7 clause-by-clause control mapping. Highlights:

  • §III — Model inventory → Entity Engine (every model is a KYEID).
  • §IV — Effective challenge → Decision Engine + Replay-Proof™.
  • §V — Documentation + change → Operating Model + signed state-transition events.
  • §V — Outcomes + monitoring → Drift cascade + Reconciliation Engine.
  • §VI — Governance + roles → GovernedUI™ Action Approval (two-person + two-person-with-legal).

Next: ISO/IEC 42001 — AI management system, in 8 minutes