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Twenty-four Asks of the RBI: A Detailed Comment on the 2026 Model Risk Management Draft

A clause-by-clause comment record on the RBI's 2026 draft Guidance on Model Risk Management. Proportionality, definitions, the black-box validation problem at paragraph 46, kill-switch operationalisation, DPDPA interaction, and a phased 18, 24, 36 month rollout. Twenty-four asks in one place.