The Analytics of Risk Model Validation || Determinants of small business default**The authors thank Jim Papadonis for his support of this research project. We also thank seminar participants at the Office of the Comptroller of the Currency, Office of Federal Housing Enterprise Oversight, Brent Ambrose, Michael Carhill, John Driscoll, Ronel Elul, Tom Lutton, Larry Mielnicki, and Nick Souleles for helpful discussion and comments. We are grateful to Diana Andrade, Ron Kwolek, and Tim Murphy for their excellent research assistance. The views expressed in this research are those of the authors and do not represent the policies or positions of the Office of the Comptroller of the Currency, of any offices, agencies, or instrumentalities of the United States Government, or of the Federal Reserve Bank of Chicago.