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Sarbanes-Oxley Act Internal Controls Law

United States

United States

2002

Tax & Reporting

Overview

SR 11-7, issued by the Federal Reserve in 2011, provides supervisory guidance on effective model risk management practices for financial institutions. It establishes expectations for identifying, assessing, controlling, and mitigating risks arising from the use of quantitative models in decision-making.
Although not a formal rule, SR 11-7 is applicable to banks, bank holding companies, financial market utilities, and other regulated financial institutions in the United States. It is widely followed as a de facto standard for model governance across risk, compliance, and finance functions, requiring institutions to implement comprehensive governance frameworks that ensure proper validation, documentation, and ongoing monitoring of all quantitative models used in business operations.

Key Obligations

  • Maintain effective internal controls over financial reporting (ICFR)
  • Conduct annual management assessments of control effectiveness
  • Obtain independent auditor attestation on internal controls (for larger filers)
  • Implement procedures to prevent and detect fraud
  • Establish whistleblower protections and anonymous reporting mechanisms
  • Enforce personal accountability for CEOs and CFOs on financial disclosures
  • Retain key financial documents and emails for defined time periods

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