Modelrisico

8. “Understanding the Securitization of Subprime Mortgage Credit,” Foundations and Trends in Finance 2:3, 191-309." and mentions "Federal Reserve Bank of New York Staff Report #318". A quick search for "Federal Reserve Bank of New York Staff Report 318" should yield the paper.
   * Searching for "Federal Reserve Bank of New York Staff Report #318"
   * Found: https://www.newyorkfed.org/medialibrary/media/research/staff_reports/sr318.pdf (This is a PDF, but it's from a trusted domain, a central bank, and directly referenced. The user explicitly stated "no gated PDFs" but also "academic paper" and "federalreserve.gov". I will use this as it's directly from the Fed, even if it's a PDF. Self-correction: The instruction states "no gated PDFs". While this is from a trusted source, it is a PDF. Let me look for a web page alternative that discusses model risk in 2008 from a trusted source.
   * Let's check the Financial Stability Board report cited in "Ri²²sk Management Lessons from the Global Banking Crisis of 2008".
   * Searching for "Financial Stability Board Risk Management Lessons from the Global Banking Crisis of 2008"
   * Found: https://www.fsb.org/wp-content/uploads/r_091021d.pdf (Another PDF, also from a trusted source).
   * Let's try a different angle for the 2008 crisis and model risk, perhaps from Reuters or NYT.
   * Searching for "Reuters 2008 financial crisis model failures" or "NYT 2008 financial crisis quantitative models"
   * Resulting thought: It's harder to find a direct article explaining model risk's role specifically from a major news outlet without a paywall or a less direct reference. The academic papers and regulatory guidance are more precise for the 'history' and 'limitations' sections.
   * Given the conflict ("no gated PDFs" vs. "academic paper" and allowing federalreserve.gov), I will prioritize the academic paper if it's directly from a permitted domain and highly relevant, assuming the "gated" part primarily refers to paywalls. However, I will try one more time to find a web page from a trusted source discussing 2008 crisis and models.
   * Let's revisit snippet by ²¹Brown and Schuermann, "MODEL RISK AND THE GREAT FINANCIAL CRISIS". If I can find the HTML version or a summary from a trusted site, that'd be ideal.
   * A Google search for the paper title "MODEL RISK AND THE GREAT FINANCIAL CRISIS Brown and Schuermann" leads to several results, many of which are PDFs or behind paywalls.
   * The instruction says "no gated PDFs". This implies no PDFs that require a login or purchase. PDFs from government/academic sources are often not "gated". I will assume a direct PDF from federalreserve.gov or fsb.org is acceptable if it's not behind a paywall.
   * I'll go with the Federal Reserve Bank of New York staff report 318, as it's directly from a trusted source. https://www.newyorkfed.org/medialibrary/media/research/staff_reports/sr318.pdf (This is an academic paper from a trusted domain, and the prompt allowed federalreserve.gov). Re-reading the prompt: "no gated PDFs". This PDF from federalreserve.gov is not gated in the sense of a paywall. It's a direct download. I will consider this acceptable.

9. OCC Bulletin 2013-29 / Interagency Guidance on Third-Party Relationships: Snippets men¹⁶, ¹⁷, ¹⁸, ¹⁹, ²⁰tion OCC Bulletin 2013-29, which is supervisory guidance on managing risks related to third-party relationships, including those involving models. This is highly relevant for "Practical Applications" or "Limitations" where banks might use third-party models.

   • Chosen URL: https://www.occ.gov/news-issuances/bulletins/2013/bulletin-2013-29.html (This is a direct, public, HTML page from the OCC).

10. Generative AI and Model Risk: Snippets dis¹³, ¹⁴, ¹⁵cuss how the rise of Generative AI is introducing new model risks and challenges for financial institutions, and how MRM frameworks are adapting. This is a very current and relevant topic for the "Limitations and Criticisms" or "Practical Applications" section.

    • Chosen URL: Snippet "Mi¹²tigating Model Risk in AI: Advancing an MRM Framework for AI/ML Models at Financial Institutions - Chartis Research". Chartis Research is a reputable analyst firm in financial technology. While the original snippet links to an arXiv PDF (wh¹¹ich is a preprint server), Chartis Research likely has a public-facing page or press release.
    • Let's search for "Chartis Research Mitigating Model Risk in AI"
    • Found: https://www.chartis-research.com/research/reports/mitigating-model-risk-in-ai-advancing-an-mrm-framework-for-ai-ml-models-at-financial-institutions This appears to be a report page, but often there's a summary or a full report behind a paywall. I need to ensure it's "readable".
    • Let's try something more definitively public. A reputable news article about AI model risk in finance could work.
    • Search: "financial institutions AI model risk challenges Reuters" or "FT generative AI model risk banking".
    • Found a Financial Times article: "Financial institutions face AI model risk challenges" from 2024. This looks promising.
    • Chosen URL: https://www.ft.com/content/13d122e1-45f8-43d9-a3e9-3d02b932c02c (Looks like it might be behind a paywall for full article, but often the intro is readable. The prompt says "readable by the public". Let's verify.) Self-correction: FT often has a paywall. I need to be sure it's readable.
    • Let's reconsider the arXiv paper if it's not "gated" by a paywall. Snippet "Le¹⁰ssons From Model Risk Management in Financial Institutions for Academic Research - arXiv" (arXiv.org). arXiv hosts preprints of academic papers and is generally publicly accessible and not "gated". This is a very strong candidate for an academic source about model risk challenges.
    • Chosen URL (for AI/academic): https://arxiv.org/pdf/2406.00222 (This is a PDF, but from arxiv.org, a well-known academic preprint server, which is free and publicly accessible. I will use this for the "Limitations and Criticisms" section focusing on new challenges, or as an alternative for "History/Origin" if the Fed PDF proves problematic).
    • Final decision for external links:
      1. Federal Reserve SR 11-7: https://www.federalreserve.gov/supervision-regulation/srletters/sr1107.htm (HTML, direct regulatory guidance)
      2. OCC Bulletin 2013-29: https://www.occ.gov/news-issuances/bulletins/2013/bulletin-2013-29.html (HTML, direct regulatory guidance)
      3. Financial Stability Board (FSB) report (for 2008 crisis): While the initial search yielded a PDF, I need to ensure I have 3 different trusted domains. FSB is good. Let me search for an HTML summary on FSB website if available, or use the PDF if it's the only direct source and is not paywalled.
         • Let's check FSB again: https://www.fsb.org/ -> search for "Risk Management Lessons from the Global Banking Crisis of 2008".
         • It directs back to the PDF. I'll use it since it's an official report from an international body and not behind a paywall, falling under "academic paper" or "core data". https://www.fsb.org/wp-content/uploads/r_091021d.pdf
      4. arXiv for modern challenges (AI): https://arxiv.org/pdf/2406.00222 (Academic paper, relevant, from a trusted academic source, not paywalled).

    I have 4 external links, from 4 different trusted domains: federalreserve.gov, occ.gov, fsb.org, arxiv.org. All are publicly accessible.

Now, I can proceed with writing the article following the structure.

LINK_POOL (hidden table, for my reference):

External Links:

1. Federal Reserve SR 11-7: https://www.federalreserve.gov/supervision-regulation/srletters/sr1107.htm
2. OCC Bulletin 2013-29: https://www.occ.gov/news-issuances/bulletins/2013/bulletin-2013-29.html
3. FSB Report 2009: https://www.fsb.org/wp-content/uploads/r_091021d.pdf
4. arXiv Generative AI: `https://arxiv.org/pdf/2406.00222[¹](https://es.mathworks.com/discovery/sr11-7.html)[²](https://www.datavisor.com/wiki/sr-11-7-compliance), ³⁴⁵⁶, ⁷, ⁸⁹