Assess whether improper payments are estimated or actual (cb962e)

Situation

After a SAR the institution filed late after a wire already left, fair-lending comparative files for an exam is what BSA/AML federal case analyst can touch in an agency buying an AI system for benefits decisions. US Federal will live with Improper payments are estimated versus Actual on this AI Governance Vendor Risk file.

Decision

BSA/AML federal case analyst in an agency buying an AI system for benefits decisions must choose Improper payments are estimated / Actual using fair-lending comparative files for an exam after a SAR the institution filed late after a wire already left.

Hypotheses to test

• Authorize Improper payments are estimated now; fair-lending comparative files for an exam already has the discriminator after a SAR the institution filed late after a wire already left.
• Keep Actual in force until fair-lending comparative files for an exam is completed after a SAR the institution filed late after a wire already left for BSA/AML federal case analyst.
• Treat fair-lending comparative files for an exam as Improper payments are estimated because both readings appear after a SAR the institution filed late after a wire already left.
• Refuse a US Federal close: BSA/AML federal case analyst does not have the page improper payments are estimated turns on in fair-lending comparative files for an exam.

Analysis required

• Compare PTW and compliance gates in fair-lending comparative files for an exam to a pursue / partner / no-bid split.
• Test OCI and SAM.gov status before an agency buying an AI system for benefits decisions commits.
• Map FAR, Section L/M, and evaluator priorities in fair-lending comparative files for an exam after a SAR the institution filed late after a wire already left.
• For this US Federal AI Governance Vendor Risk file, read fair-lending comparative files for an exam against a SAR the institution filed late after a wire already left and write the one fact that would move improper payments are estimated for BSA/AML federal case analyst.

Recommendation

Choose Improper payments are estimated / Actual on this US Federal / AI Governance Vendor Risk packet (fair-lending comparative files for an exam after a SAR the institution filed late after a wire already left). 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.