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.
To be clear, that doesn't refute the point I am making.
For anyone who suspects it might (I'm not sure how...) consider this: a model of the Titanic (or a replica, for that matter) is not the Titanic. A model of your brain would neither be your brain nor necessarily a brain at all, but whether it could think is a different question.