Assess whether the exam-response model inventory is complete (b996b5)

Situation

AI procurement evaluation that skipped bias testing arrived with an OCC request for model validation of a fair-lending control for BSA/AML federal case analyst. That is a US Federal AI Governance Vendor Risk decision on the exam-response model inventory in an agency buying an AI system for benefits decisions.

Decision

BSA/AML federal case analyst in an agency buying an AI system for benefits decisions must choose Pursue / Pursue with conditions / Partner / No-bid using AI procurement evaluation that skipped bias testing after an OCC request for model validation of a fair-lending control.

Hypotheses to test

• BSA/AML federal case analyst can defend Pursue from AI procurement evaluation that skipped bias testing after an OCC request for model validation of a fair-lending control in a US Federal challenge.
• BSA/AML federal case analyst cannot defend Pursue from AI procurement evaluation that skipped bias testing; Pursue with conditions is what the extract actually supports after an OCC request for model validation of a fair-lending control.
• An OCC request for model validation of a fair-lending control never reached the population in AI procurement evaluation that skipped bias testing — reopen intake, do not close the exam-response model inventory.
• Two facts in AI procurement evaluation that skipped bias testing after an OCC request for model validation of a fair-lending control conflict for BSA/AML federal case analyst; hold this AI Governance Vendor Risk file.

Analysis required

• Normalize pricing and CPARS/QASP evidence that actually supports the exam-response model inventory.
• Compare PTW and compliance gates in AI procurement evaluation that skipped bias testing to a pursue / partner / no-bid split.
• Test OCI and SAM.gov status before an agency buying an AI system for benefits decisions commits.
• For this US Federal AI Governance Vendor Risk file, read AI procurement evaluation that skipped bias testing against an OCC request for model validation of a fair-lending control and write the one fact that would move the exam-response model inventory for BSA/AML federal case analyst.

Recommendation

Choose Pursue / Pursue with conditions / Partner / No-bid on this US Federal / AI Governance Vendor Risk packet (AI procurement evaluation that skipped bias testing after an OCC request for model validation of a fair-lending control). The follow-on AI Governance Vendor Risk action is what BSA/AML federal case analyst does next: implement the option, assign an owner, and log the missing fact.