Corvair Knowledge Substrate · Mobile (Application user)

INQ-204

tuneFilters shieldT1, T2 eventAs of: Live sortRelevance

What model risk requirements under SR 11-7 apply before we promote CS-204 to production?

neurologyAveryVirtual expert

SR 11-7 frames model risk around development, validation, and governance. For CS-204, the gates sit in the first two.

An independent validation covering conceptual soundness, outcomes analysis, and monitoring is required before deployment, performed by staff independent of development. Documentation must let a third party reproduce the model.

Because CS-204 informs consumer credit, fair-lending testing and an effective-challenge record should accompany the package. Your MRM policy also requires a board-approved Tier-1 rating, which CS-204 lacks.

Bottom line: CS-204 cannot be promoted until independent validation is complete and a board-approved Tier-1 rating is issued.

checkIndependent validation is mandatory pre-production

checkReproducible development documentation required

checkFair-lending testing for consumer credit

closeOpen blocker: no board-approved rating

▸ SR 11-7 three pillars
development · validation · governance
▸ Pre-production gates
independent validation · reproducible docs
▸ Consumer-credit add-ons
fair lending · effective challenge
▸ Open blocker
Tier-1 board rating

account_treePremise chain

CS-204 is a Tier-1 modelT1

Independent validation required pre-productionT1

Tier-1 needs a board-approved ratingT2

privacy_tipOne identifier was redacted by policy. For an authorised task, declare a purpose.

verified_user

Validity warrant issued

WRNT-204-7 · requested by CJ, in policy

attach_fileAttach from Vaultformat is on the answer

Map EU AI Act Articles 9–15 to our internal model-risk controls and flag gaps.

helpCLARIFIED BEFORE STARTING

Which articles are in scope?Art. 9–15 (risk, data, documentation, transparency, human oversight)

What output do you want?A control-mapping table plus a list of gaps

How deep, and which sources?Standard depth · prefer T1 and T2 · internal policy first

account_treeREASONING PLAN · captured

check1 · Plan. Broke the objective into seven sub-questions.

check2 · Initial search. EU AI Act text and 38 internal sources.

check3 · Reflect. Two clusters were thin on internal evidence.

check4 · Follow-up. Four targeted searches for oversight and logging.

check5 · Synthesise. Aligned each obligation to a control.

progress_activity6 · Improve. Confirming the two gaps. 71%

schedule7 · Choose format. Mapping table plus gap list.

schedule8 · Produce output. Render the report and issue a warrant.

Report · drafting

Draft, updating as the run completes. Articles 9–15 map cleanly onto existing model-risk controls in most areas. Two obligations have no current internal control.

Art. 9 · Risk management system

MRM-STD-01 model risk framework

Mapped

Art. 10 · Data and data governance

DATA-GOV-03 data quality and lineage

Mapped

Art. 11 · Technical documentation

CS-204 development record v4

Mapped

Art. 12 · Record-keeping and logging

No internal control

Gap

Art. 13 · Transparency to deployers

MODEL-CARD-02 disclosure pack

Mapped

Art. 14 · Human oversight

No internal control

Gap

Art. 15 · Accuracy and robustness

MRM-STD-02 validation standard

Mapped

Two gaps to close. Article 12 needs an automatic logging and retention control for the model's decisions, and Article 14 needs a documented human-oversight procedure for the credit-decisioning use of CS-204.

verified_user

Warrant on completion

RES-118 · pending final step

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