The model is oversimplistic - reductionist:
There is evidence for different types of LTM e.g. Tulving states that there is semantic and episodic LTM
Baddeley and Hitch state that there are different types of STM
Ignores the interaction between the STM and LTM e.g. chunking requires meaning from the LTM
Over emphasis on rehearsal - elaborate rehearsal can improve recall better than maintenance rehearsal