Validating a US Bank's Internal Fraud Model for submission to Regulators
Client: Global Financial Service Organization
Objective
Validate a US Bank's model for detecting employees committing consumer-account and credit-card fraud for CCAR submission.
CRISIL's Solution
The CRISIL team performed a comprehensive validation of the model, a simple formula-based scoring model, to identify anomalies based on data grouping using expert judgment. We used the following process:
- Data Validation: Validated data sources for their relevance and timeliness, and assessed the quality checks made by the developer;
- Conceptual Soundness Check: The model development team was queried on various tested methodologies and assumptions, and assessed the responses qualitatively;
- Analysis of Tables and Results: The CRISIL team validated the tables and results provided in the model development document and performed backward computation to check the model's conceptual soundness assessment.
Client Impact
- The model was validated and the Internal Fraud Validation Document was completed within the stringent deadline for CCAR submission.
- The model was awarded a patent by the US Patents and Trademark Office.
Questions