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Why Mortgage Rates Fell Even as the 10-Year Rose
As I’ve mentioned in a few recent posts, even though the Fed has started lowering short rates, the longer end of the curve has remained flat and even ticked up a bit. For example, the 10-year Treasury is up about 10 basis points since the Fed lowered rates. Despite this, mortgage rates have actually come down significantly, from around 6.9% in late May on a 30-yr fixed rate to around 6.30% in early October. What’s driving that? One big factor has been spread tightening in th
Oct 152 min read


Right-Sizing Model Risk Management
Model risk management isn’t one-size-fits-all. On October 6, 2025, the OCC issued Bulletin 2025-26 ( https://lnkd.in/diiunKRc ), reminding community banks that model risk practices, including how often models are validated, should be right-sized to an institution’s complexity, resources, and risk profile. I was glad to see the OCC explicitly say it does not expect every model to be validated every year. I’ve long believed that a thoughtful, risk-based approach beats a blanket
Oct 151 min read


Bull Steepener Ahead: What It Means for CRE and Balance Sheet Risk
It looks like we are headed into a bull steepener yield curve scenario. ↘️ Front-end treasury rates (2-year) are already coming down as markets price in multiple Fed cuts. Futures show an 87% chance for a 25pbs cut in Sept, 54% for another 25bps in October and a 43% chance for an additional 25bps at the December meeting. ↗️ Yet the 10-year remains stubbornly high. This is likely a pivot point in the rate cycle and institutions should be stress-testing their balance sheet. ✔
Aug 182 min read


When Rules Become Risk: Treating BSA/AML Systems as Models
But it's not a model!! This might sound obvious to most of us as BSA/AML transaction monitoring systems have been treated as models for...
Jul 312 min read


The Hidden Risk in AML Programs: Poor Data Governance
We all know the saying as it relates to model data: 🚮 garbage in, garbage out 🚮 . 🚨 But when it comes to AML models, the stakes are...
Jul 311 min read


Q2 2025 CECL Trends: What the Latest KPMG Survey Reveals
As most banks and credit unions work to calculate and finalize their Q2 2025 CECL reserves, KPMG released their Q2 CECL Pulse Check survey ( https://shorturl.at/FJaBi ) and I wanted to share some takeaways. They surveyed 23 banks and 4 finance firms and the results were not surprising. A few things that stood out: - Forecasting remains a big challenge as 88% cited economic outlooks (especially government-driven ones) as the toughest part of ACL estimation. - Economic uncertai
Jul 132 min read


Rethinking Liquidity Stress Testing in Today’s Environment
In an environment marked by rising funding costs, increased deposit mobility, persistent unrealized losses in bond portfolios, and...
Jul 132 min read


Deposits Webinar - Avoiding Hidden Risks in Interest Rate and Liquidity Risk Management
I had the opportunity yesterday (July 2025) to present a webinar to nCino's Portfolio Analytics clients on a topic that continues to be...
Jul 132 min read


FDIC’s Q1 2025 Banking Profile: Solid at a Glance, But Look Again
The FDIC published its quarterly banking profile for Q1 2025 yesterday. While the report looks "solid" on the surface, once you dive in a...
Jul 132 min read


Certified ≠ Validated: Know the Difference
If your institution relies on vendor models, this might save you from costly missteps and regulatory headaches. 🛑 Model Certifications ≠...
Jul 132 min read


Digital Dollars, Real Risk: What Stablecoins Mean for Model Risk
I’ve always been intrigued by crypto and the blockchain. But mostly from a distance as I'm pretty risk averse on the personal investing...
Jul 132 min read


A Better Approach to Model Validation: Practical, Thoughtful, Useful
Let’s be real - no one really gets too excited about a model validation. For many model owners, it can feel like a frustrating drain on...
Jul 132 min read


OCC’s Spring 2025 Risk Report: No Shocks, But CRE Still Looms
The OCC just released its Spring 2025 Semiannual Risk Perspective and, for community banks, it mostly backed up what we already know. 🏢...
Jul 132 min read


Principles That Guide Our Work at ValuRisk Partners
Now that I’ve launched my own firm, ValuRisk Partners, I’ve been reflecting on some of the lessons that have shaped how I approach model...
Jul 132 min read


Effective Liquidity Stress Testing Starts with a Coherent Narrative
One of the most common pitfalls in liquidity stress testing is using scenarios that escalate in severity but lack internal consistency....
Jul 122 min read


The Strategic Value of a Thorough CECL Validation
For many financial institutions, CECL implementation was a heavy lift - one that checked a regulatory compliance box and moved on. But...
May 112 min read


Interest Rate Risk Isn’t About Prediction - It’s About Preparation
Intricate geometric glass ceiling reflecting the sky, creating a mesmerizing pattern of blue squares. Why Model Integrity and Scenario...
May 112 min read


Why a Robust Liquidity Stress Testing Process is Critical in Today’s Volatile Environment
In an era marked by rapid interest rate shifts, evolving depositor behavior, and geopolitical uncertainty, financial institutions can no...
May 83 min read


Striking the Balance: Collaboration Between the 1st and 2nd Lines of Defense in Model Risk Management
In today’s highly regulated and data-driven financial environment, models are at the heart of decision-making, from credit underwriting...
May 62 min read
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