This seems to be correct - it appears to be the "a model is not that which it models" argument, which is Searle's only response to the Simulation Reply to his Chinese Room - but a model of a thing can have properties of that thing (a model boat can float, create a wake etc.), and an informational process can be modeled by another. Are minds informational processes instantiated by brains? It is plausible, and the model argument does not rule it out.