Documenting the incidents: Which activity does this call for?
Capturing each reversal, its root cause, residual risk and forward monitoring is documenting incidents, issues and risks together with the post-market monitoring plan.
The question
After a deployed loan-scoring model twice produced results that had to be reversed, governance wants a durable record capturing each event, its root cause, the residual risk, and how the system will be watched going forward. Which activity does this call for?
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- Reviewing the vendor agreement's liability and indemnification clause termsA reasonable step, but contract review allocates commercial risk rather than creating the operational incident record described.
- Documenting the incidents, issues, risks and post-market monitoring plan ✓Recording each reversal, its cause, residual risk and forward monitoring is exactly incident/issue/risk documentation with a monitoring plan.
- Conducting periodic red teaming of the loan-scoring model's defensesA valid assessment, yet adversarial testing probes for weaknesses instead of documenting incidents that already occurred.
- Applying additional user training for the loan officers using the toolPotentially helpful, but training staff does not produce the durable record of incidents and monitoring being requested.
The trap
Jumping to a mitigation such as training or testing when the requirement is the documented incident-and-monitoring record itself. How to remember it
Capturing each reversal, its root cause, residual risk and forward monitoring is documenting incidents, issues and risks together with the post-market monitoring plan.
How many of these would you get right?
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