US counsel and industry feel that the regulatory clampdown on banks' use of internal risk models is likely to result in increased capital charges. The regulatory push back against internal models takes different forms. In the US, one such is the supervisory guidance on model risk management, better known as SR 11-7 and released by the Federal Reserve Board (FRB) and the Office of the Comptroller of the Currency (OCC) in 2011. While the guidance applies only to banks in the US, it's becoming a global standard.