ead the following draft model risk policy below. Please make 2-3 suggestions on how to improve the policy. Please explain the reasoning behind your suggestions.

Purpose: This policy is meant to provide the primary objectives of the Model Risk Management for the bank. It is also meant to provide clear definitions on model and model risk and give clear rules on how model satisfies compliance to the MRM policy. This includes requirements for vendor models.

This policy defines a model as quantitative method, system, or approach that applies statistical, economic, financial, or mathematical theories, techniques, and assumptions to process input data into quantitative estimates.

Model Risk is assessed via the measurements of certain KRIs and KCIs in the Model Lifecycle to ensure that model risk is always within the risk appetite set by the BoD.

The BoD delegates the overall management of model risk to the Model Risk Management (MRM) department inside the firm. The head of MRM will report into the CRO.

Organizational Structure: Business Units are deemed as principal model owners and are responsible for the 1^st LoD duties such as proper development and use of the models. Model Developers share this responsibility with the Business Units.

Independent Model Validation Team is responsible for the 2^nd LoD duty of the validation control process. The Independent Model Validation Team must give an approve or reject outcome to each validation exercise.

All models are expected to be validated for initial use and re-validated annually for continued use.

All models must be registered in the banks model inventory system.