Three model risk management leaders from Capital One, New York Life, and TIAA, including an advisor who contributed to the original SR 11-7, gathered at Rev New York to assess what SR 26-2 changes and where it leaves institutions exposed.
The panel's perspective on the guidance was clear: SR 26-2 is a refinement of SR 11-7, not a replacement. The materiality provisions give institutions a stronger foundation for tiering their validation work, and the flexibility is real. But the exclusion of generative and agentic AI from scope is where the harder governance work begins. As one panelist from the session observed, the guidance arrived well-constructed for the traditional side of the model inventory and as an acknowledged placeholder for the rest.
For agentic AI risk management specifically, the panel moved away from technical model definitions and agreed on a risk-based inventory approach organized around reasoning complexity, autonomy, and impact. Institutions are left with open problems that SR 26-2 does not address: vendor models embedded with AI, agentic orchestration layers, and existing validation limits for frameworks handling variable AI outputs.
The strategic posture the panel recommended is to build your parallel governance framework for generative and agentic systems now, engage examiners proactively, and treat the forthcoming regulatory comment process as an opportunity to shape what comes next.