During an AI audit, the team finds that an AI-based insurance underwriting model was retrained with new data but the new version was deployed without a change impact assessment or validation. What MOST accurately describes the governance failure?

The breach of the model change management process, bypassing required validation for material model changes, is correct because model change management processes ensure that even updates to existing models undergo appropriate impact assessment and validation before deployment. Retraining with new data constitutes a material change that can alter model behavior significantly. Bypassing this process is a governance failure independent of other concerns. Failure to maintain adequate training data documentation is a related concern but not the primary failure. Violation of data residency requirements by using new data sources without privacy review and insufficient model monitoring because post-deployment performance was not tracked are separate concerns.