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.

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