For a validator and a developer, the arrangements of the ECB guide are: (a) two units reporting to different members of senior management; (b) two units reporting to the same member of senior management; (c) separate staff within one unit. A validator who reports, directly or through a manager, to the model’s developer or owner is not independent at all.
firm.roles.independence: (a) different members of senior management; (b) different units under one senior manager; (c) separate staff in one unit; “fail”: the validator reports to the owner of the model it reviews. Senior management here is the chief risk officer and the head of markets. Data: in_bankquant.org_cases.