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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
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
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
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
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