The April 2026 interagency guidance that replaced SR 11-7 — SR 26-2, OCC Bulletin 2026-13, FDIC FIL-15-2026 — puts generative and agentic AI outside its scope, with a request for information still to come. Your model risk function has an open question and no supervisory answer yet, so we document against the framework you already run.
Every system ships with a validation pack: model inventory entry, documented intended use and limitations, the evaluation methodology and results against your own case set, prompt and model version control, and a change log that triggers revalidation when either moves.
This matters more than it sounds. A managed AI vendor can update its model without telling you — leaving your validation covering a version you’re no longer running. Systems built here are model-agnostic and run in your environment, so your MRM function controls the version and the change cycle.
To be explicit about independence: this documentation is first-line evidence for your independent validation function to review. It is not a substitute for independent validation.