Response to OCC MRM examination

Inquiry received 2026-04-14 · Response due 2026-04-28 (9 days remaining)

DRAFT · EDITABLE

To: Office of the Comptroller of the Currency · Attn: J. Whitfield, Lead Examiner
Re: MRM Sound Practices · Reference OCC-2026-Q1-MRM-0412

Dear Examiner Whitfield,

We are writing in response to the inquiry dated April 14, 2026 regarding Meridian Financial Group's adherence to SR 11-7 and OCC 2011-12 sound practices for model risk management, specifically concerning CreditRisk-v3 validation cadence.

We confirm that CreditRisk-v3 underwent SR 11-7 revalidation on April 17, 2026. The validation identified three findings (two material, one non-material) and resulted in a conditional approval with three enforced conditions:

1. Application of +80bps PD overlay on CRE exposures effective next batch cycle
2. Delivery of recalibrated v3.1 using Q4 2025–2026 data by June 15, 2026
3. Restoration of monthly challenger cadence, effective immediately

The sign-off was executed by U. Sinha (Head of Model Risk Management) at 23:20 UTC on April 19, 2026. The approval receipt is cryptographically chained in our governance ledger (receipt #47,291, SHA-256 9c4e28a1…).

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