No subprocessor or sub-model register
One model (MDL-001 Claims triage) runs on a third-party provider that is not named in any approved record. "A leading commercial provider" is not an answer a reviewer can write down. The carrier has to name every third party in its own examination response, so an unnamed provider makes your gap their finding, and a reviewer who cannot close a question in their own file will stop and ask rather than accept it.
To fix: Name every model provider, hosting region, and data processor that touches insurer data, with contract reference and an accountable owner. A single approved table is enough, as long as it is kept current.