# Control 2.6 — Troubleshooting: Model Risk Management (OCC Bulletin 2026-13 / SR 26-2 — formerly OCC 2011-12 / SR 11-7) Evidence Pipeline and Examination Readiness

> **Scope.** This playbook is the diagnostic companion to [Control 2.6 — Model Risk Management (OCC Bulletin 2026-13 / SR 26-2 — formerly OCC 2011-12 / SR 11-7)](../../../controls/pillar-2-management/2.6-model-risk-management-sr-26-2.md). It addresses operational failure modes in the **evidence pipeline** the firm relies on to satisfy SR 26-2 (formerly SR 11-7) — the model inventory (DSPM for AI), the underlying-model change-detection path (Microsoft Copilot Studio + Message Center), the validation evidence chain (Foundry evaluators, Committee minutes, validation memos), the 17a-4(f)-compliant retention path, the publication-approval workflow in Agent 365, sovereign-cloud parity gaps, the PowerShell helpers used to produce examiner-ready inventories, and examination-readiness rehearsal.
>
> **Regulatory framing.** Reliable evidence produced by the surfaces in this control *supports compliance with* OCC Bulletin 2026-13 (formerly OCC Bulletin 2011-12), Federal Reserve SR 26-2 (formerly SR 11-7), FDIC FIL-22-2017, FFIEC IT Handbook, FINRA Rule 3110 (Supervision), FINRA Rule 4511 and SEC 17a-3 / 17a-4 (Books and Records — including 17a-4(f) WORM retention of validation evidence and Committee minutes), SOX §§ 302 / 404 (ICFR documentation of AI controls), GLBA 501(b), and NYDFS 23 NYCRR 500 where AI agents touch covered customer information. FINRA RN 25-07 (workplace modernization RFC) is referenced **as contextual material only** and is not cited as an enforceable AI rule. The Microsoft surfaces described here **support** the firm's MRM program; they **do not replace** the firm's Model Risk Management Committee, the independent validation function, the effective-challenge process, three-lines-of-defense governance, or registered-principal supervisory review under FINRA Rule 3110.
>
> **Audience.** Power Platform Admin, Purview Compliance Admin, AI Administrator, Compliance Officer, AI Governance Lead, Model Risk Manager, and second-line MRM staff supporting the firm's response to internal audit, examiner pulls, and Committee inquiries.
>
> **Sibling playbooks.** [portal-walkthrough.md](portal-walkthrough.md) · [powershell-setup.md](powershell-setup.md) · [verification-testing.md](verification-testing.md)

---

!!! warning "Non-Substitution — Tooling Supports MRM, It Does Not Replace It"
    Every diagnostic, helper, and remediation step in this playbook produces or repairs **evidence**. None of them performs validation, exercises effective challenge, or makes a model-tiering or approval decision. Those judgments are reserved to the firm's Model Risk Management Committee, the independent validation function (organizationally separate from the model owner per SR 26-2 §V (formerly SR 11-7 §V)), and registered-principal supervision under FINRA Rule 3110. Any examiner-facing communication arising from an incident in this playbook must be coordinated through Compliance and Legal — **not** by individual administrators acting on their own.

---

## Table of Contents

- [§0 Triage Tree](#0-triage-tree)
- [§1 Issue 1 — DSPM for AI Inventory Missing Agents](#1-issue-1-dspm-for-ai-inventory-missing-agents)
- [§2 Issue 2 — Default-Model Migration Not Detected Before It Took Effect](#2-issue-2-default-model-migration-not-detected-before-it-took-effect)
- [§3 Issue 3 — Independent Validation Challenged Because Validator Reports to Model Owner](#3-issue-3-independent-validation-challenged-because-validator-reports-to-model-owner)
- [§4 Issue 4 — Anthropic Claude (or Other Vendor Model) Selected Without Vendor-Model Assessment](#4-issue-4-anthropic-claude-or-other-vendor-model-selected-without-vendor-model-assessment)
- [§5 Issue 5 — Foundry Evaluator Runs Missing for Tier 1 Agent](#5-issue-5-foundry-evaluator-runs-missing-for-tier-1-agent)
- [§6 Issue 6 — Effective-Challenge Evidence Weak: Committee Minutes Generic](#6-issue-6-effective-challenge-evidence-weak-committee-minutes-generic)
- [§7 Issue 7 — Validation Evidence Retention Not 17a-4(f)-Compliant](#7-issue-7-validation-evidence-retention-not-17a-4f-compliant)
- [§8 Issue 8 — Agent 365 Publication-Approval Workflow Not Blocking Publish](#8-issue-8-agent-365-publication-approval-workflow-not-blocking-publish)
- [§9 Issue 9 — GCC / GCC High / DoD Tenant: Foundry Evaluators or DSPM for AI Not Available](#9-issue-9-gcc-gcc-high-dod-tenant-foundry-evaluators-or-dspm-for-ai-not-available)
- [§10 Issue 10 — Model-Retirement Evidence Missing](#10-issue-10-model-retirement-evidence-missing)
- [§11 Issue 11 — PowerShell Helper Returns Status=Error](#11-issue-11-powershell-helper-returns-statuserror)
- [§12 Issue 12 — Examiner Asks for Inventory of In-Scope Agents and Firm Cannot Produce in Real Time](#12-issue-12-examiner-asks-for-inventory-of-in-scope-agents-and-firm-cannot-produce-in-real-time)
- [§13 Escalation Paths](#13-escalation-paths)
- [§14 Cross-References](#14-cross-references)

---

## §0 Triage Tree

### 0.1 Symptom → Issue Map

| # | Presenting Symptom | Likely Issue | First Diagnostic |
|---|---|---|---|
| 1 | Agent visible in Power Platform Admin Center / Agent 365 but absent from DSPM for AI inventory | [§1](#1-issue-1-dspm-for-ai-inventory-missing-agents) | License / region / connector audit |
| 2 | Agent Card references a model no longer in production; vendor migrated default | [§2](#2-issue-2-default-model-migration-not-detected-before-it-took-effect) | Message Center subscription audit |
| 3 | Examiner challenges validator independence — validator reports to model owner | [§3](#3-issue-3-independent-validation-challenged-because-validator-reports-to-model-owner) | Org-chart trace + MRM charter |
| 4 | Vendor model (e.g., Anthropic Claude) selected in Copilot Studio without vendor-model assessment | [§4](#4-issue-4-anthropic-claude-or-other-vendor-model-selected-without-vendor-model-assessment) | Agent Card vs. approved-model list |
| 5 | Tier 1 agent has no Foundry evaluator runs; outcomes-analysis evidence gap | [§5](#5-issue-5-foundry-evaluator-runs-missing-for-tier-1-agent) | Foundry evaluator history |
| 6 | Committee minutes describe approvals in generic terms; effective-challenge evidence weak | [§6](#6-issue-6-effective-challenge-evidence-weak-committee-minutes-generic) | Minute-template review |
| 7 | Validation memos / Committee minutes stored only in M365 Audit Premium or general SharePoint | [§7](#7-issue-7-validation-evidence-retention-not-17a-4f-compliant) | Retention-label / WORM audit |
| 8 | Agent 365 publication-approval workflow does not block publish for non-MRM-approved agents | [§8](#8-issue-8-agent-365-publication-approval-workflow-not-blocking-publish) | Governance template scope check |
| 9 | Sovereign tenant — Foundry evaluators / DSPM for AI not surfaced | [§9](#9-issue-9-gcc-gcc-high-dod-tenant-foundry-evaluators-or-dspm-for-ai-not-available) | Sovereign roadmap re-verification |
| 10 | Tier 1 agent retired; decision, last validation, and final monitoring snapshot not retained | [§10](#10-issue-10-model-retirement-evidence-missing) | Change-history reconstruction |
| 11 | PowerShell helper returns `Status=Error` | [§11](#11-issue-11-powershell-helper-returns-statuserror) | Module / connection / endpoint check |
| 12 | Examiner asks for in-scope agent inventory in real time and firm cannot produce | [§12](#12-issue-12-examiner-asks-for-inventory-of-in-scope-agents-and-firm-cannot-produce-in-real-time) | On-demand PS helper + rehearsal review |

### 0.2 Severity Matrix

| Severity | Criteria | Response Target | Notifications |
|---|---|---|---|
| **SEV-1** | Examiner / regulator on-the-clock; inventory cannot be produced; or material model change detected post-fact in production for a Tier 1 agent | Triage within 1h; mitigation within 4h | AI Governance Lead, MRM Committee Chair, Compliance Officer, Legal |
| **SEV-2** | Tier 1 outcomes-analysis evidence missing; validator-independence finding; vendor model in production without assessment | Triage within 4h; mitigation within 24h | AI Governance Lead, Model Risk Manager, Compliance Officer |
| **SEV-3** | Tier 2 evidence gap; Committee-minute template defect; publication-workflow misconfiguration with no Tier 1 exposure | Triage within 1 business day | Model Risk Manager, AI Governance Lead |
| **SEV-4** | Tier 3 evidence gap; cosmetic / reporting defect | Triage within 5 business days | AI Governance Lead |

### 0.3 Pre-Remediation Checklist

Before taking any remediation action recorded in this playbook:

1. **Preserve current state.** Snapshot the affected agent's Agent Card, model-inventory row, current validation memo, and most recent Committee disposition to a Purview-retention-protected location before edits.
2. **Confirm scope.** Tier (1 / 2 / 3), Zone (1 / 2 / 3), tenant cloud (Commercial / GCC / GCC High / DoD), business owner, and whether the agent is customer-facing or decision-support.
3. **Examination flag.** Confirm with Compliance / Legal whether the affected agent is subject to an active examination, internal investigation, subpoena, or litigation hold. If yes, proceed only under written direction.
4. **Reserve MRM judgment.** Record that any remediation produces or repairs **evidence**; the MRM Committee retains the substantive validation, tiering, and approval decisions.

---

## §1 Issue 1 — DSPM for AI Inventory Missing Agents

**Symptom.** One or more agents are visible in Power Platform Admin Center, Copilot Studio, or the Agent 365 console, but do not appear in Microsoft Purview **DSPM for AI** > **Discover** > **AI applications**. The model inventory the firm relies on for examination response is incomplete.

**Root causes (typical).**

- **License gap.** DSPM for AI requires Purview / Compliance Manager licensing tied to the tenant; affected agents may sit in an environment whose owner is not licensed for DSPM for AI.
- **Region / rollout lag.** DSPM for AI feature rollout proceeds wave-by-wave by region and tenant. Newly provisioned tenants or recently created environments may not have completed first-time discovery.
- **Connector enablement.** The Copilot, Copilot Studio, Foundry, and Entra-registered-AI-app connectors in DSPM for AI are individually enableable; one or more may be off in the tenant.
- **Identity / Entra Agent ID propagation lag.** Agents not yet registered in Entra Agent ID (Control 2.26) may be invisible to the DSPM for AI discovery surface that pivots on Entra identity.
- **Sovereign-cloud parity gap.** DSPM for AI rollout in **GCC, GCC High, and DoD lags commercial**. As of the verification date in this document, full evaluator and connector parity has not been confirmed across sovereign clouds. Treat sovereign tenants as compensating-control tenants until parity is verified per [Issue 9](#9-issue-9-gcc-gcc-high-dod-tenant-foundry-evaluators-or-dspm-for-ai-not-available).

**Resolution.**

1. **License audit.** Confirm tenant-level Purview / Compliance Manager license assignment and that the environment owner principals are licensed. Open a ticket with the tenant licensing administrator if a gap is found.
2. **Connector audit.** In Purview > **Settings** > **DSPM for AI** > **Connectors**, confirm that Copilot, Copilot Studio, Foundry, and Entra-registered AI app connectors are enabled. Where a connector is disabled, document the business reason; if there is none, enable it under change control.
3. **Force a discovery pass.** In commercial cloud, the DSPM for AI inventory refresh is on a service-managed cadence and cannot be forced by the customer. Document the expected refresh window (verify the current SLA in Microsoft Learn) and re-check after the window has elapsed.
4. **Cross-check with Power Platform admin export.** Use the inventory PowerShell helper from [`powershell-setup.md`](powershell-setup.md) to enumerate agents from the Power Platform admin endpoint, and diff against the DSPM for AI export. Investigate every agent present in one source and not the other.
5. **Sovereign-cloud caveat.** If the tenant is GCC, GCC High, or DoD, **do not assume DSPM for AI inventory is authoritative**. Operate the [§9](#9-issue-9-gcc-gcc-high-dod-tenant-foundry-evaluators-or-dspm-for-ai-not-available) compensating-control inventory (manual SharePoint list backed by Purview retention) as the inventory of record, and use any DSPM for AI data that is available as a corroborating source only.

**Verification.**

- Re-run the inventory diff after the documented refresh window. The DSPM for AI inventory and the Power Platform admin enumeration agree to ±0 agents, or every delta has a documented reason.
- License and connector audit findings are recorded in the change ticket and signed off by the AI Governance Lead.

**Cross-link.** [Control 2.25 — Agent 365 Admin Center Governance Console](../../../controls/pillar-2-management/2.25-agent-365-admin-center-governance-console.md) · [Control 2.26 — Entra Agent ID Identity Governance](../../../controls/pillar-2-management/2.26-entra-agent-id-identity-governance.md) · [Control 3.1 — Agent Inventory and Metadata Management](../../../controls/pillar-3-reporting/3.1-agent-inventory-and-metadata-management.md).

---

## §2 Issue 2 — Default-Model Migration Not Detected Before It Took Effect

**Symptom.** Microsoft migrated the default underlying foundation model in Copilot Studio (for example, GPT-family default upgrade or replacement). The firm's Agent Card for one or more agents now references a model that is no longer the production default, and no impact assessment was performed before the migration took effect. The MRM Committee learned of the change after deployment.

**Root causes (typical).**

- **No subscription to vendor change signals.** The Microsoft 365 Message Center, the Power Platform release plan, and the Copilot Studio "What's new" feed are not routed to a monitored mailbox / Teams channel staffed by the AI Administrator and the Model Risk Manager.
- **Agent Card records "Copilot Studio default" rather than the specific model and version.** When the default rolls forward, the Agent Card silently changes meaning.
- **No change-management gate** treating an underlying-model change as a model change under SR 26-2 §VI (formerly SR 11-7 §VI).

**Resolution.**

1. **Subscribe vendor change signals to a monitored mailbox.** Route the Microsoft 365 Message Center, Power Platform release plan, and Copilot Studio release notes to a shared mailbox / Teams channel with the AI Administrator, AI Governance Lead, Model Risk Manager, and second-line MRM as members. Document the subscription owners and the SLA for triage of model-impacting messages (recommended: 1 business day).
2. **Update Agent Card schema.** Require the Agent Card to record **specific underlying model and version** (e.g., `gpt-5-2026-03`, not `Copilot Studio default`). Re-issue Agent Cards for every in-scope agent in the inventory.
3. **Treat the migration as a model change.** Under SR 26-2 §VI (formerly SR 11-7 §VI), a vendor-driven default-model migration is a model change. Open a change ticket per agent, perform impact assessment proportionate to tier (Tier 1: full re-validation; Tier 2: abbreviated re-validation; Tier 3: documented review), and obtain MRM Committee disposition.
4. **Backfill evidence.** For the migration that took effect without prior assessment, document the gap in the Committee minutes, the date the firm became aware, the post-fact impact assessment, and any compensating monitoring (e.g., enhanced Foundry evaluator cadence for the next monitoring period).

**Verification.**

- Message Center routing produces a triage record within the documented SLA on the next vendor-issued model-change message (test by waiting for, or simulating receipt of, a representative message).
- 100% of in-scope Agent Cards record specific model and version.
- Committee minutes for the next cycle reflect the post-fact impact assessment for the missed migration.

**Cross-link.** [Control 2.3 — Change Management and Release Planning](../../../controls/pillar-2-management/2.3-change-management-and-release-planning.md) · [Control 2.7 — Vendor and Third-Party Risk Management](../../../controls/pillar-2-management/2.7-vendor-and-third-party-risk-management.md).

---

## §3 Issue 3 — Independent Validation Challenged Because Validator Reports to Model Owner

**Symptom.** During an examination, internal audit, or Committee review, a finding is raised that the validator who signed the validation memo for one or more agents reports — directly or via dotted line — to the model owner / model developer. SR 26-2 §V (formerly SR 11-7 §V) independence test failed.

**Root causes (typical).**

- Validation function was stood up inside the first line of defense (within the business that owns the model) rather than in the second line.
- MRM charter does not explicitly require organizational independence between validator and model owner.
- Resource pressure led to first-line staff being asked to validate work produced by colleagues in the same reporting chain.

**Resolution.**

1. **Re-route validators to second-line MRM.** Reassign the validation function to personnel organizationally and functionally separate from the model owner / developer (SR 26-2 §V (formerly SR 11-7 §V)). Internal second-line MRM staff can satisfy independence; third-party engagement is one way to demonstrate it but is **not required** and is **not equivalent** to the regulatory independence test.
2. **Document organizational independence in the MRM charter.** Update the firm's Model Risk Management policy / charter to explicitly state: (a) the reporting line of the validation function, (b) that validators have authority and competence to challenge the model, and (c) the prohibition on validators sitting in the same reporting chain as the model owner. Obtain MRM Committee approval and Compliance sign-off.
3. **Re-validate affected agents.** For every agent whose validation is challenged, perform a new validation by an organizationally independent validator. Retain both memos: the original (with the noted independence finding) and the re-validation, with a cover memo explaining the remediation. Do not delete the original.
4. **Retain remediation evidence.** Route the original memo, the independence finding, the charter update, the re-validation memo, and the Committee disposition to the 17a-4(f)-compliant retention path (see [§7](#7-issue-7-validation-evidence-retention-not-17a-4f-compliant)).

**Verification.**

- The MRM charter version with explicit independence language is published, dated, and signed off by the Committee.
- An organizational chart trace from each validator to the model owner shows no shared reporting line short of a sufficiently senior independent officer (typically the CRO or equivalent).
- Re-validation memos for affected agents are filed and accepted by the Committee.

**Cross-link.** [Control 2.7 — Vendor and Third-Party Risk Management](../../../controls/pillar-2-management/2.7-vendor-and-third-party-risk-management.md) · [Control 2.12 — Supervision and Oversight (FINRA Rule 3110)](../../../controls/pillar-2-management/2.12-supervision-and-oversight-finra-rule-3110.md).

---

## §4 Issue 4 — Anthropic Claude (or Other Vendor Model) Selected Without Vendor-Model Assessment

**Symptom.** Review of an Agent Card or Copilot Studio model-selection screen shows an agent configured to use a third-party / vendor model (for example, Anthropic Claude where available in the firm's tenant) without a documented vendor-model assessment. SR 26-2 §V (formerly SR 11-7 §V) vendor-model governance gap.

**Root causes (typical).**

- Copilot Studio surfaces vendor models in the model-selection UI as availability rolls out; agent owners may select a vendor model without recognizing the vendor-model governance obligation.
- No technical guardrail (Power Platform DLP / governance template) restricts vendor-model selection in Zones 2 / 3.
- MRM policy does not yet enumerate vendor-model providers or pre-approval status.

**Resolution.**

1. **Quarantine or dispose.** Pending assessment, the MRM Committee may direct the agent owner to either (a) revert to a pre-approved model on the firm's approved-model list, or (b) restrict the agent to Zone 1 / non-production use until assessment completes. Record the disposition.
2. **Perform post-hoc vendor-model assessment.** Apply the firm's vendor-model assessment under SR 26-2 §V (formerly SR 11-7 §V) — covering the vendor's model documentation, training-data disclosures, evaluation results, sovereign-cloud availability, terms-of-service review, data-handling commitments, and the vendor's incident-disclosure history. Coordinate with Vendor Risk Management (Control 2.7).
3. **MRM Committee disposition.** The Committee renders an explicit disposition: approved / approved-with-conditions / not approved. Disposition, conditions, and effective dates are recorded in Committee minutes and routed to retention.
4. **Update Agent Card and approved-model list.** Update the Agent Card to record the specific vendor model and version, the assessment reference, and the Committee disposition. Update the firm's approved-model list and re-publish to model owners.
5. **Add a technical guardrail (forward-looking).** Where supported, configure Power Platform DLP and / or the Agent 365 governance template so that selection of a non-approved vendor model in Zone 2 / 3 either blocks publish or routes through an approval workflow (see [Issue 8](#8-issue-8-agent-365-publication-approval-workflow-not-blocking-publish)).

**Verification.**

- Vendor-model assessment memo is filed with Committee disposition.
- Agent Card reflects the specific vendor model, version, and approval reference.
- Subsequent attempts to select a non-approved vendor model in Zone 2 / 3 are intercepted by the configured guardrail (test in Zone 1 first).

**Cross-link.** [Control 2.7 — Vendor and Third-Party Risk Management](../../../controls/pillar-2-management/2.7-vendor-and-third-party-risk-management.md) · [Control 2.3 — Change Management and Release Planning](../../../controls/pillar-2-management/2.3-change-management-and-release-planning.md).

---

## §5 Issue 5 — Foundry Evaluator Runs Missing for Tier 1 Agent

**Symptom.** A Tier 1 agent has no Azure AI Foundry evaluator runs in the current monitoring period, or the most recent evaluator run is older than the cadence specified in the firm's MRM policy. The outcomes-analysis pillar of SR 26-2 (formerly SR 11-7) has an evidence gap.

**Root causes (typical).**

- Foundry project for the agent was never linked to the Copilot Studio agent / endpoint.
- Evaluator suite was scoped at design time but not scheduled, or schedule was disabled after a quota change.
- Evaluation dataset is empty or stale; runs were skipped because no inputs were available.
- Sovereign-cloud parity gap — Foundry evaluators are not yet available in the tenant's cloud (see [Issue 9](#9-issue-9-gcc-gcc-high-dod-tenant-foundry-evaluators-or-dspm-for-ai-not-available)).

**Resolution.**

1. **Configure the Foundry built-in evaluators.** For each Tier 1 agent, configure the relevant subset of Foundry built-in evaluators against a representative evaluation dataset:
    - **Quality:** groundedness, relevance, coherence, fluency.
    - **Safety:** content-safety / harm evaluators (verify per region and judge-model availability).
    - **Agentic behavior:** tool-call accuracy, task completion.
2. **Curate a representative evaluation dataset.** The dataset must reflect the agent's production use cases, including known edge cases, adversarial prompts, and golden-answer cases. The dataset is itself an MRM artifact and must be versioned and retained.
3. **Document cadence in MRM policy.** The MRM policy should specify evaluator cadence by tier — for example, Tier 1 monthly, Tier 2 quarterly, Tier 3 annually or on material change. Cadence is set by the firm; the values above are illustrative.
4. **Schedule and monitor the runs.** Configure the runs on the documented cadence; route run-failure alerts to a monitored channel. Backfill the missed period by running the evaluator suite against the current production configuration and recording the gap as a finding.
5. **Reserve MRM judgment.** Foundry evaluator output is **evidence** consumed by validators; it does not constitute validation in itself. The Committee remains responsible for outcomes-analysis disposition.

**Verification.**

- Foundry evaluator history shows runs at the documented cadence for every Tier 1 agent.
- Evaluation dataset is versioned and retained under the 17a-4(f) path.
- Backfill memo is filed with the Committee.

**Cross-link.** [Control 1.7 — Comprehensive Audit Logging and Compliance](../../../controls/pillar-1-security/1.7-comprehensive-audit-logging-and-compliance.md) · [Control 3.9 — Microsoft Sentinel Integration](../../../controls/pillar-3-reporting/3.9-microsoft-sentinel-integration.md).

---

## §6 Issue 6 — Effective-Challenge Evidence Weak: Committee Minutes Generic

**Symptom.** Internal audit or examiner review finds Committee minutes that record approvals in generic terms ("the Committee reviewed and approved") without capturing the specific challenge questions raised, validator responses, disposition rationale, dissenting views, or follow-up actions. Effective-challenge evidence under SR 26-2 (formerly SR 11-7) is weak.

**Root causes (typical).**

- Minute template is summary-only and does not prompt the secretary to capture challenge specifics.
- Discussion happens in the room but is not transcribed into the record.
- Follow-up actions are tracked outside the minutes (in a separate tracker), making it difficult to demonstrate closure during examination.

**Resolution.**

1. **Overhaul the minute template.** The new template, at minimum, captures per-agenda-item:
    - **Specific challenge questions** raised by Committee members or invited challengers.
    - **Validator / model-owner responses** to each challenge.
    - **Disposition** (approved / approved-with-conditions / deferred / not approved) with rationale.
    - **Dissenting views** and the names of dissenting members.
    - **Follow-up actions** with owner, due date, and the agenda item where closure will be reported.
2. **Pre-meeting challenge package.** Require the secretary to circulate a challenge package in advance of the meeting (validation memo, Foundry evaluator results, prior findings, open follow-ups). Capture in the minutes which materials were reviewed.
3. **Re-issue prior minutes only on Legal direction.** Do not retroactively edit historical minutes. If a historical minute is materially incomplete, file a **supplemental memo** with the dated correction, signed by the Committee Chair, and route both the original and the supplement to retention.
4. **Train the secretary.** Brief the Committee secretary on the new template and the SR 26-2 (formerly SR 11-7) effective-challenge standard. Record the training as evidence of remediation.

**Verification.**

- The next Committee meeting produces minutes that pass a documented quality review against the new template.
- A sample of three subsequent meetings confirms sustained adoption.
- Open follow-ups are visibly tracked across meetings.

**Cross-link.** [Control 2.12 — Supervision and Oversight (FINRA Rule 3110)](../../../controls/pillar-2-management/2.12-supervision-and-oversight-finra-rule-3110.md) · [Control 1.7 — Comprehensive Audit Logging and Compliance](../../../controls/pillar-1-security/1.7-comprehensive-audit-logging-and-compliance.md).

---

## §7 Issue 7 — Validation Evidence Retention Not 17a-4(f)-Compliant

**Symptom.** Validation memos, Committee minutes, vendor-model assessments, and / or Foundry evaluator results are stored only in **M365 Audit Premium** logs or in a general-purpose SharePoint site without an immutable retention label. Retention does not meet SEC 17a-4(f) for books-and-records of model artifacts.

> **Important.** **M365 Audit Premium is operational telemetry** for activity audit (extended retention up to one year for Premium SKUs). It is **not** 17a-4(f) WORM-compliant retention for model artifacts and validation evidence. Long-term model documentation and validation evidence must land in **Microsoft Purview retention with an immutable / record-label policy** or be routed to an **approved 17a-4(f) third-party vendor** (e.g., Cohasset-attested archival service).

**Root causes (typical).**

- Retention design treated audit-log retention and books-and-records retention as the same problem.
- SharePoint sites used by MRM lack a configured Purview retention label or have a label that permits modification / deletion before the retention period expires.
- No formal mapping exists between MRM artifact types and the 17a-4(f) retention path.

**Resolution.**

1. **Define the retention map.** Map each MRM artifact type (validation memo, Committee minute, vendor-model assessment, Foundry evaluator dataset and results, Agent Card version, change-ticket package, model-retirement memo) to its retention class, retention period, and storage path.
2. **Apply Purview retention labels.** Configure or update Purview retention labels with **records / regulatory record** behavior so that protected items cannot be modified or deleted before the retention period expires. Apply the labels to the MRM SharePoint sites and / or to the specific document libraries that hold model artifacts. Validate label inheritance.
3. **Or route to an approved 17a-4(f) vendor.** Where the firm uses an approved third-party archive (Cohasset-attested or equivalent), route the artifact via the documented connector and retain the connector's confirmation of receipt and immutability attestation.
4. **Backfill historical artifacts.** For artifacts already in non-compliant locations, copy them under change control to the compliant store, apply the retention label / archival route, and record the move in a remediation memo. Retain the originals in place where deletion is not authorized.
5. **Decouple from M365 Audit Premium.** Do not rely on M365 Audit Premium retention for model artifacts. Audit Premium remains useful for operational telemetry and for evidencing access to the artifacts.

**Verification.**

- Retention-label policy report shows 100% of MRM artifact libraries covered by a records-class label.
- An attempt to delete a protected artifact (test in Zone 1 with a non-evidence document) is blocked by the label.
- Vendor-archive confirmations exist for any artifact routed to an external 17a-4(f) vendor.

**Cross-link.** [Control 1.7 — Comprehensive Audit Logging and Compliance](../../../controls/pillar-1-security/1.7-comprehensive-audit-logging-and-compliance.md) · [Control 1.9 — Data Retention and Deletion Policies](../../../controls/pillar-1-security/1.9-data-retention-and-deletion-policies.md).

---

## §8 Issue 8 — Agent 365 Publication-Approval Workflow Not Blocking Publish

**Symptom.** An agent is published to Zone 2 / Zone 3 without MRM Committee approval. The Agent 365 publication-approval workflow exists but did not block the publish action. The governance template is not enforced.

**Root causes (typical).**

- Governance template was authored at tenant scope but not bound to the relevant environment(s).
- Template was applied to the environment but the publication-approval policy within it is in **report-only** mode rather than **enforce**.
- The publishing principal has an admin-tier role that bypasses governance template enforcement.
- A new environment was created after template binding and was not re-bound.

**Resolution.**

1. **Re-apply the governance template at environment scope.** In Agent 365 Admin Center, confirm the governance template is bound to every in-scope environment, and that the publication-approval policy within the template is in **enforce** mode (not report-only).
2. **Audit bypass roles.** Enumerate principals with roles that bypass governance template enforcement. Restrict these roles to a small documented set of break-glass identities, and record any use in the change ticket and Sentinel (Control 3.9).
3. **Verify only MRM-Committee-approved agents publish.** The workflow must check, before allowing publish to Zone 2 / 3, that the agent's inventory record has a current Committee disposition of "approved" and that no blocking conditions are open. Where the workflow integrates with the inventory store (Dataverse / SharePoint), confirm the check.
4. **Backfill remediation for the agent that slipped through.** Treat the unapproved publication as a control failure. Quarantine or unpublish the agent pending Committee disposition; document the slip in Committee minutes; route the remediation memo to retention.
5. **Re-bind on environment creation.** Add a process step to the environment-provisioning runbook that re-binds the governance template before any agent can publish.

**Verification.**

- Governance template is bound to 100% of in-scope environments and is in enforce mode.
- A test publish attempt for an agent without Committee disposition is blocked (test in Zone 1).
- Bypass-role inventory is documented and minimized.

**Cross-link.** [Control 2.25 — Agent 365 Admin Center Governance Console](../../../controls/pillar-2-management/2.25-agent-365-admin-center-governance-console.md) · [Control 2.3 — Change Management and Release Planning](../../../controls/pillar-2-management/2.3-change-management-and-release-planning.md).

---

## §9 Issue 9 — GCC / GCC High / DoD Tenant: Foundry Evaluators or DSPM for AI Not Available

**Symptom.** The tenant operates in GCC, GCC High, or DoD. One or more of the surfaces this control depends on — DSPM for AI, Foundry evaluators (especially safety evaluators that depend on commercial-cloud-hosted judge models), the Agent 365 Admin Center governance console, Entra Agent ID lifecycle workflows, or Anthropic Claude / other vendor models in Copilot Studio — is not available, is in limited preview, or has reduced parity. Sovereign parity gap.

**Root causes (typical).**

- Microsoft surface availability in sovereign clouds is independently gated and lags commercial GA.
- Some Foundry safety evaluators rely on judge models hosted in commercial cloud and are not yet operational in sovereign clouds.
- Third-party model availability (e.g., Anthropic Claude) in sovereign clouds is independently gated by both the third party and Microsoft.

**Resolution.**

1. **Invoke compensating manual controls** until Microsoft confirms parity for the affected surface:
    - **Manual model inventory.** Maintain a SharePoint list (backed by a Purview retention label, see [§7](#7-issue-7-validation-evidence-retention-not-17a-4f-compliant)) covering every AI agent that meets the firm's model-classification criteria. Treat this list as the inventory of record in sovereign clouds.
    - **Manual validation by the firm's MRM function.** Perform validation under the firm's existing model risk policy, using the Foundry evaluator suite where available and substituting documented manual evaluation (golden-dataset regression, SME review, sampling) where Foundry is not.
    - **17a-4(f) retention for all artifacts.** All MRM artifacts go to the 17a-4(f)-compliant path described in [§7](#7-issue-7-validation-evidence-retention-not-17a-4f-compliant).
2. **Document the sovereign-parity gap as an explicit finding.** The firm's MRM policy / WSPs and the Committee minutes should record which surfaces are unavailable, which compensating controls are in force, and the re-verification cadence.
3. **Re-verify quarterly.** Re-check parity quarterly via the [Microsoft 365 Government roadmap](https://aka.ms/m365gov-roadmap) and the Azure Government / DoD service status pages. Record each re-verification in the Committee minutes. As surfaces become available, plan a controlled migration from compensating controls to the automated path.
4. **Do not represent the compensating-control posture as equivalent to the commercial-cloud automated path** in examiner-facing communications. Disclose the sovereign-parity posture honestly.

**Verification.**

- Manual model-inventory SharePoint list exists, is retention-labeled, and is current.
- Quarterly re-verification memo is filed with the Committee.
- Compensating-control posture is described in MRM policy and Committee minutes.

**Cross-link.** [Control 2.25 — Agent 365 Admin Center Governance Console](../../../controls/pillar-2-management/2.25-agent-365-admin-center-governance-console.md) · [Control 2.26 — Entra Agent ID Identity Governance](../../../controls/pillar-2-management/2.26-entra-agent-id-identity-governance.md) · [Control 2.7 — Vendor and Third-Party Risk Management](../../../controls/pillar-2-management/2.7-vendor-and-third-party-risk-management.md).

---

## §10 Issue 10 — Model-Retirement Evidence Missing

**Symptom.** A Tier 1 agent was retired, but the firm cannot produce, on demand, the **retirement decision** (who, when, why), the **last validation memo** that was current at retirement, and the **final monitoring snapshot** (Foundry evaluator results, Copilot Studio analytics, Agent 365 usage). Retired-model evidence gap.

**Root causes (typical).**

- Retirement was treated as a deletion / decommissioning task rather than as a model lifecycle event.
- No retirement workflow existed to capture the artifacts before the underlying surfaces were torn down.
- Inventory record was deleted instead of being marked retired with retention preserved.

**Resolution.**

1. **Reconstruct the artifacts retroactively.**
    - **Decision and timing.** Reconstruct from change history (Power Platform admin change log), Sentinel events (Control 3.9), unified audit log (Control 1.7), and the change ticket.
    - **Last validation memo.** Retrieve from the 17a-4(f) retention path; if the memo was never routed there, retrieve from the original SharePoint location and route under change control.
    - **Final monitoring snapshot.** Retrieve from Foundry evaluator history (within retention window), Copilot Studio analytics export (where retained), and any Sentinel events captured around the retirement window.
2. **File a reconstruction memo.** Document the reconstruction methodology, the sources used, the gaps that could not be reconstructed (with rationale), and Committee disposition. The reconstruction memo itself becomes evidence and is routed to retention.
3. **Update the model-retirement workflow going forward.** Add explicit steps to the workflow:
    - Capture the retirement decision (Committee minute reference, owner, effective date).
    - Snapshot the current Agent Card, validation memo, Foundry evaluator dataset and results, and final monitoring report.
    - Route all artifacts to 17a-4(f) retention before any underlying surface is torn down.
    - Mark the inventory record **retired** (do not delete); retain the inventory row for the longer of the regulatory retention period and the firm's policy.
4. **Drill the workflow.** Run a tabletop exercise on the next planned retirement to confirm the workflow operates end-to-end.

**Verification.**

- Reconstruction memo is filed and accepted by the Committee.
- The updated model-retirement workflow is published, owned, and referenced in the MRM policy.
- The next planned retirement produces a complete artifact set on first attempt.

**Cross-link.** [Control 1.7 — Comprehensive Audit Logging and Compliance](../../../controls/pillar-1-security/1.7-comprehensive-audit-logging-and-compliance.md) · [Control 1.9 — Data Retention and Deletion Policies](../../../controls/pillar-1-security/1.9-data-retention-and-deletion-policies.md) · [Control 3.9 — Microsoft Sentinel Integration](../../../controls/pillar-3-reporting/3.9-microsoft-sentinel-integration.md).

---

## §11 Issue 11 — PowerShell Helper Returns Status=Error

**Symptom.** A PowerShell helper from [`powershell-setup.md`](powershell-setup.md) (model-inventory enumeration, manifest export, MRM compliance report, model-change monitoring, end-to-end configuration) returns `Status=Error`, throws an unhandled exception, or exits non-zero.

**Common causes and resolutions.**

| Cause | Symptom | Resolution |
|---|---|---|
| **Microsoft Graph throttling (HTTP 429)** | Intermittent failures on inventory enumeration; `Retry-After` header in error | Apply exponential backoff per [`_shared/powershell-baseline.md`](../../_shared/powershell-baseline.md); reduce page size; partition by environment |
| **Required module missing or wrong version** | `The term 'Add-PowerAppsAccount' is not recognized`; cmdlet-not-found | Pin module versions per the baseline; reinstall with `-Force -Scope CurrentUser`; verify with `Get-Module -ListAvailable` |
| **Not connected to Power Platform admin endpoint** | `Unauthorized`; empty result sets | Re-run `Add-PowerAppsAccount` (or the service-principal variant); confirm the connection token has not expired |
| **Not connected to Exchange Online** | `Search-UnifiedAuditLog` not recognized | Re-run `Connect-ExchangeOnline` with the appropriate role assignment |
| **Sovereign endpoint mismatch** | Connections appear to succeed but return commercial-cloud data, or fail with TLS / endpoint errors | Set the `-Endpoint` parameter explicitly per the baseline (GCC / GCC High / DoD endpoints differ); verify with the baseline's endpoint table |
| **Insufficient role assignment** | `Forbidden` on specific endpoints | Confirm the executing principal holds the documented roles (Power Platform Admin, Entra Global Reader for inventory, Purview Compliance Admin where DSPM for AI is queried) |
| **Dataverse compatibility** | Date / decimal serialization mismatch | Use the baseline's Dataverse-safe serialization helpers; do not pass raw `[datetime]` to Dataverse without ISO-8601 conversion |
| **Missing inventory CSV / file path** | `[WARN] Model inventory not found` | Confirm the `-ModelInventoryPath` parameter resolves to a real file; the helper will create a template if absent — verify the template was not committed as production inventory |

**Resolution (general).**

1. Re-read [**PowerShell Authoring Baseline for FSI Implementations**](../../_shared/powershell-baseline.md). It is the authoritative source for module pinning, sovereign endpoint selection, mutation safety (`-WhatIf` / `SupportsShouldProcess`), and SHA-256 evidence emission.
2. Run the helper with `-Verbose` and `-Debug` to surface the failing call.
3. For Graph throttling, capture the `Retry-After` header and back off; for persistent throttling, open a Microsoft Support case.
4. For sovereign endpoint mismatches, never assume commercial-cloud defaults — set endpoints explicitly.
5. Capture the failing run output and command line in the incident record before retrying.

**Verification.**

- Helper completes with `Status=OK` and emits the documented evidence artifact (CSV / JSON / HTML).
- For sovereign tenants, output references the sovereign endpoint used.

**Cross-link.** [`_shared/powershell-baseline.md`](../../_shared/powershell-baseline.md) · [Control 3.9 — Microsoft Sentinel Integration](../../../controls/pillar-3-reporting/3.9-microsoft-sentinel-integration.md).

---

## §12 Issue 12 — Examiner Asks for Inventory of In-Scope Agents and Firm Cannot Produce in Real Time

**Symptom.** A regulator (OCC, Federal Reserve, SEC, FINRA, FDIC, NYDFS) requests, during an examination, an inventory of AI agents the firm treats as models under SR 26-2 (formerly SR 11-7). The firm cannot produce the inventory within the requested window (typically same-day or next business day for routine pulls). Process and tooling gap.

**Root causes (typical).**

- Inventory exists as a manually maintained SharePoint list updated quarterly; the as-of inventory at the examiner's requested date is reconstructable but not at-hand.
- Multiple inventory sources (DSPM for AI, Power Platform admin, manual SharePoint) have not been reconciled and the firm cannot determine which is authoritative.
- No examination-readiness rehearsal has been performed; the runbook to assemble the response packet does not exist.

**Resolution.**

1. **Stand up a quarterly inventory pull as the standing baseline.** Use the inventory PowerShell helper from [`powershell-setup.md`](powershell-setup.md) on a scheduled quarterly cadence; sign and route the output to 17a-4(f) retention as the as-of-quarter inventory of record. The as-of-quarter snapshots become the firm's defensible baseline for examiner pulls.
2. **Pre-stage an ad-hoc on-demand query.** Document and rehearse the procedure to run the helper on demand against the current state, reconcile against DSPM for AI and the manual list, and produce an examiner-ready package within a documented SLA (recommended: same business day for routine pulls).
3. **Pre-stage an examination-readiness rehearsal.** At least annually — ideally semi-annually — run a tabletop exercise: a senior officer (Compliance Officer or designee) issues a simulated examiner request; the team executes the procedure; the AI Governance Lead reviews the package for completeness, hedged language, and alignment with the MRM policy. Record the rehearsal as a finding-and-remediation cycle.
4. **Designate a single inventory of record.** The MRM policy must designate which of DSPM for AI, the Power Platform admin enumeration, or the manual SharePoint list is the inventory of record. The other sources are corroborating. Reconciliation deltas are tracked as findings until closed.
5. **Coordinate examiner-facing communications through Compliance and Legal.** No individual administrator transmits inventory or evidence directly to a regulator. The package is reviewed and transmitted by Compliance / Legal.

**Verification.**

- Quarterly inventory snapshots exist for the trailing four quarters under 17a-4(f) retention.
- The ad-hoc procedure has been rehearsed within the trailing 12 months and the rehearsal record is filed.
- The MRM policy designates the inventory of record.

**Cross-link.** [Control 3.1 — Agent Inventory and Metadata Management](../../../controls/pillar-3-reporting/3.1-agent-inventory-and-metadata-management.md) · [Control 1.9 — Data Retention and Deletion Policies](../../../controls/pillar-1-security/1.9-data-retention-and-deletion-policies.md) · [Control 2.12 — Supervision and Oversight (FINRA Rule 3110)](../../../controls/pillar-2-management/2.12-supervision-and-oversight-finra-rule-3110.md).

---

## §13 Escalation Paths

The matrix below describes **when** to escalate and to **whom**. Substantive MRM judgments — model tiering, validation disposition, effective challenge, model retirement — are reserved to the MRM Committee and the independent validation function and are not delegable to administrators.

| Trigger | Escalate To | Purpose |
|---|---|---|
| Tier 1 agent in production with missing or stale validation evidence | **MRM Committee** (Chair + Model Risk Manager) | Validation disposition; quarantine or compensating-control direction |
| Validator-independence finding (SR 26-2 §V (formerly SR 11-7 §V)) | **MRM Committee** + **Compliance Officer** | Charter remediation; re-validation direction |
| Vendor model in production without assessment | **MRM Committee** + **Vendor Risk Management** (Control 2.7) | Vendor-model assessment; disposition |
| Material model change (vendor-driven default migration) detected post-fact for Tier 1 | **MRM Committee** + **Compliance Officer** | Impact assessment; disclosure decision |
| 17a-4(f) retention gap on validation evidence or Committee minutes | **Compliance Officer** + **Records Management** | Books-and-records remediation; potential self-disclosure decision |
| Examiner / regulator request the firm cannot satisfy in-window | **Compliance Officer** + **Legal** (immediate) | All examiner-facing communications coordinated; rehearsal failure tracked as a finding |
| Subpoena, litigation hold, or active examination touching an in-scope agent | **Legal** (immediate) | Preservation direction; remediation gating |
| Microsoft surface defect impacting MRM evidence (DSPM for AI, Foundry evaluators, Agent 365) | **Microsoft Support** (Premier / Unified per the firm's contract) | Vendor-side root-cause and resolution; evidence collection for the firm's record |
| Sovereign-parity gap that materially constrains the firm's MRM posture | **MRM Committee** + **Compliance Officer** | Compensating-control approval; quarterly re-verification owner |
| Cross-jurisdictional examination, novel regulatory question, or potential rule violation | **External counsel** (via Legal) | Specialist guidance |

**Examiner-facing communication — non-delegation.** No administrator, helper script, or evidence-collection tool transmits inventory, validation memos, Committee minutes, or any other record directly to a regulator, examiner, or external auditor. **All examiner-facing communications are coordinated through Compliance and Legal.** Administrators provide the underlying evidence artifacts on request and, where appropriate, attend in a technical-support capacity at the direction of Compliance / Legal.

**Microsoft Support engagement.** When opening a Premier / Unified Support case for a surface defect, attach the diagnostic output from [§11](#11-issue-11-powershell-helper-returns-statuserror), identify the affected tenant cloud (Commercial / GCC / GCC High / DoD), and label the case severity per the firm's support contract. Retain the case correspondence as evidence; route to 17a-4(f) retention if the case touches an in-scope model artifact.

---

## §14 Cross-References

**Sibling playbooks.** [portal-walkthrough.md](portal-walkthrough.md) · [powershell-setup.md](powershell-setup.md) · [verification-testing.md](verification-testing.md)

**Closely related controls.**

- [Control 1.7 — Comprehensive Audit Logging and Compliance](../../../controls/pillar-1-security/1.7-comprehensive-audit-logging-and-compliance.md)
- [Control 1.9 — Data Retention and Deletion Policies](../../../controls/pillar-1-security/1.9-data-retention-and-deletion-policies.md)
- [Control 2.3 — Change Management and Release Planning](../../../controls/pillar-2-management/2.3-change-management-and-release-planning.md)
- [Control 2.7 — Vendor and Third-Party Risk Management](../../../controls/pillar-2-management/2.7-vendor-and-third-party-risk-management.md)
- [Control 2.12 — Supervision and Oversight (FINRA Rule 3110)](../../../controls/pillar-2-management/2.12-supervision-and-oversight-finra-rule-3110.md)
- [Control 2.25 — Agent 365 Admin Center Governance Console](../../../controls/pillar-2-management/2.25-agent-365-admin-center-governance-console.md)
- [Control 2.26 — Entra Agent ID Identity Governance](../../../controls/pillar-2-management/2.26-entra-agent-id-identity-governance.md)
- [Control 3.1 — Agent Inventory and Metadata Management](../../../controls/pillar-3-reporting/3.1-agent-inventory-and-metadata-management.md)
- [Control 3.9 — Microsoft Sentinel Integration](../../../controls/pillar-3-reporting/3.9-microsoft-sentinel-integration.md)

**Shared baselines.** [`_shared/powershell-baseline.md`](../../_shared/powershell-baseline.md)

**External references.**

- OCC Bulletin 2026-13 (formerly OCC Bulletin 2011-12) — Sound Practices for Model Risk Management
- Federal Reserve SR 26-2 (formerly SR 11-7) — Supervisory Guidance on Model Risk Management
- FDIC FIL-22-2017 — FDIC adoption of OCC Bulletin 2026-13 (formerly OCC 2011-12)
- FFIEC IT Examination Handbook — Management; Information Security
- FINRA Rule 3110 (Supervision); FINRA Rule 4511 (Books and Records)
- SEC Rule 17a-3 / 17a-4 (Recordkeeping; 17a-4(f) WORM retention)
- SOX §§ 302 / 404 (Internal Controls over Financial Reporting)
- GLBA 501(b) (Safeguards Rule); NYDFS 23 NYCRR 500
- FINRA RN 25-07 (workplace modernization — RFC, contextual only)
- [Microsoft 365 Government roadmap](https://aka.ms/m365gov-roadmap)

---

*Updated: May 2026 | Version: v1.6.2 | UI Verification Status: Current*
