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MODEL RISK OFFICER SR
The Model Risk Officer Senior is responsible for providing thought leadership on assessment of risk management framework for AI and ML models and tools, including advanced and generative AI models, with respect to regulatory guidelines and industry best practices. This position supports the bank nationally across all markets.
The role provides subject matter expertise and supports implementation of the AIML model risk framework, policy and governance, with a focus on responsible AI practices. This role provides oversight and peer review for AIML model validation. This includes effective challenge and evaluation of model results, particularly for complex and emerging AI technologies such as large language models (LLMs) and generative AI systems. This individual creates guidelines and procedures for evaluating explainability, interpretability, robustness, and bias. This role manages prioritization, scope, and frequency of validation activities. This individual evaluates model risk by highlighting the impact of potential deficiencies and weaknesses in model usage, and reports key findings and limitations to the Model Risk Manager and/or Director. This individual also provides training and support the Model Risk team members, including mentoring on AI model validation best practices.
Position Responsibilities:
Model Risk Management & Independent Model Validation
- Responsible for ensuring strong and deep understanding of AIML model risk management requirements as the subject matter expert, given regulatory expectations and industry best practices.
- Provide thought leadership and implementation of AIML model risk framework, policy, governance, and procedures.
- Support peer reviews and provide training to MRM team.
- Responsible for conducting independent model testing, including evaluation of conceptual soundness and developmental evidence, checking the model's accuracy, demonstrating robustness and stability, assessing potential limitations, and evaluating model behavior over a range of input values.
- Perform rigorous assessment of data quality, assumption relevance, and appropriate documentation, especially where management judgment or AI techniques are used.
- Provide support and training to Model Risk team, as needed.
Model Risk Governance and Reporting
- Responsible for reporting model development, implementation, use, independent validation, and controls.
- Assist the Model Risk Oversight Committee in ensuring adherence to regulatory guidelines and internal policy for model risk management and validation.
Regulatory Examination and Compliance
- Assist the Model Risk Manager/Director in managing regulatory examinations relating to the model validation process and reporting.
- Evaluate and maintain compliance with applicable regulatory rules and banking industry practices.
Position Qualifications:
- Master's Degree from an accredited university in a quantitative field such as Data Science, Statistics, Operations Research, Quantitative Finance, Econometrics, Applied mathematics, AI/ML, Applied Physics, or Engineering. Preferred PhD or strong quant background
- 5 years of progressive experience in performing high level financial or model risk analysis, particularly as it applies to the financial services industry. Strong project management experience
- 5 years of experience managing projects and leading validation initiatives in a crossfunctional environment
- 4 years of handson experience in AI/ML model development or validation, including familiarity with Python or R and modern AI frameworks (e.g., TensorFlow, PyTorch)
About Comerica
We know our employees are critical to our overall success and we are dedicated to investing in their future. One of the ways we do this is to offer a comprehensive Total Rewards package designed to recognize and reward individual performance, as well support health, well-being, development and security for our colleagues and their family. Total Rewards consists of cash compensation, development and flexible benefit programs designed to meet individual needs today and in the future. Your salary will be commensurate with your work experience and our programs are reviewed regularly to ensure each remain competitive. We are proud to offer benefits such as health and welfare programs, strong retirement benefits, and generous paid time off programs. You and your eligible family members, including domestic partners and their children, can participate in medical, dental, and vision benefits, 401(k) and pension, income protection benefits such as life insurance, AD&D, and supplemental health programs to offset unexpected health care expenses. We also have a variety of time off programs for things like vacation, sick time, disability, and parental leave. Eligibility for some programs varies based on employment status and tenure.
Upon offer, Comerica conducts a comprehensive background and fingerprint check. Your fingerprints will be used to check the criminal history records of the FBI and may be subscribed in the FBI's Record of Arrest and Prosecution Background ("RAP Back") service, which provides ongoing notification to the Company of any updates to your criminal history.
NMLS certification requirement: where applicable, a favorable background check screening, credit check, fingerprint check, and NMLS certification is required in accordance with the SAFE Act.
Comerica Incorporated (NYSE: CMA) is a financial services company headquartered in Dallas, Texas, and strategically aligned into three major business segments; the Commercial Bank, the Retail Bank, and Wealth Management. Comerica's colleagues focus on relationships, and helping people and businesses be successful. In addition to Texas, Comerica Bank locations can be found in Arizona, California, Florida and Michigan, with select businesses operating in several other states, as well as in Canada and Mexico.
Comerica is proud to be an Equal Opportunity Employer - disability/veteran.
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Comerica Bank
life insurance, parental leave, paid time off, sick time, 401(k)
Jul 16, 2025