SR 26-2 and the agentic AI governance gap for MRM leaders
September 29 | 1pm EST | Duration: 1 hour
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SR 26-2 replaces the old checklist-based approach with materiality-based tiering, changing how banks validate models. It also names generative and agentic AI as out of scope for now, with an agency request for information reportedly on the way. That leaves model risk management leaders with the real work: deciding how much governance to build before the guidance catches up.
Join Nick Goble of Domino Data Lab for an open conversation with Jason DiPalma of KeyBank and Naresh Raheja, Former OCC Senior Risk Specialist and Examiner, on how model risk leaders are building governance and handling the generative and agentic AI gap.
The conversation will cover where agentic AI governance stands today and where supervisors and institutions are likely to take it next. Attendees will hear about:
- Classifying agentic systems: How to think about agentic systems that don't map cleanly onto traditional model risk categories, and why SR 26-2's silence on generative and agentic AI is a signal to keep building governance
- Monitoring autonomous agents: How oversight requirements shift as agentic AI moves from producing an output for a person to review to taking action on its own
- Interpreting the regulatory silence: A supervisor's perspective on how agentic AI will be examined, given SR 26-2 doesn't address it directly
- Governing what you didn't build: Why third-party AI risk is becoming as hard to govern as anything developed in-house
- Determining ownership: Whether agentic AI governance belongs in the first line, the second line, or a dedicated AI council, and how to make that decision
Panelists
Jason DiPalma
SVP, Senior Director Model Risk Governance
Jason DiPalma is Senior Director of Model Risk Governance at KeyBank, where he leads enterprise model risk governance practices. With 27 years of experience within the banking and financial services industry, Jason brings a multidimensional perspective shaped by leadership roles in accounting and finance, internal audit, and model risk management across both regional and global financial institutions.
Naresh Raheja
Senior Risk Specialist & Examiner
Naresh Raheja is an AI risk and MRM leader who advises firms on balancing AI innovation with prudent risk management across machine learning, Gen AI, and agentic AI models and systems. He is a former OCC Senior Risk Specialist and Examiner. At the OCC, he supervised large banks' model risk management, AI governance, and climate-related credit and operational risk practices. In that role, he also collaborated with the Federal Reserve, Financial Stability Oversight Council (FSOC), FDIC, and international financial regulators on several initiatives.
Nick Goble
Solution Architecture for Financial Services & Insurance
Nick Goble, Ph.D. leads Solution Architecture for Financial Services & Insurance at Domino Data Lab, bringing more than ten years of experience across quantitative finance, derivatives modeling, and fintech innovation. At Venerable, Nicholas managed Quantitative Research and Development, where he established quant research capabilities from the ground up and guided teams in building sophisticated trading platforms and pricing engines. Before that, he was a Senior Quantitative Researcher at Chatham Financial, focusing on valuation methodologies and bringing machine learning models into live trading environments. Nicholas holds a Ph.D. in Physics from Case Western Reserve University.