Assess whether improper payments are estimated or actual (0b593a)

Situation

Financial Crime and Sanctions work in a bank in a fair-lending comparative-file exam now turns on improper payments are estimated because a SAR the institution filed late after a wire already left put model-risk exam request list in play. Federal banking exam-response lead should say what model-risk exam request list proves.

Decision

Federal banking exam-response lead in a bank in a fair-lending comparative-file exam must choose Improper payments are estimated / Actual using model-risk exam request list after a SAR the institution filed late after a wire already left.

Hypotheses to test

• A SAR the institution filed late after a wire already left is noise around an already-controlled Financial Crime and Sanctions process in a bank in a fair-lending comparative-file exam, given model-risk exam request list.
• A SAR the institution filed late after a wire already left is the event in model-risk exam request list that forces Improper payments are estimated for federal banking exam-response lead under US Federal.
• Model-risk exam request list shows a one-file miss after a SAR the institution filed late after a wire already left, not a Financial Crime and Sanctions program failure.
• Model-risk exam request list cannot decide improper payments are estimated yet after a SAR the institution filed late after a wire already left; hold is the only US Federal close a bank in a fair-lending comparative-file exam can defend.

Analysis required

• Test OCI and SAM.gov status before a bank in a fair-lending comparative-file exam commits.
• Map FAR, Section L/M, and evaluator priorities in model-risk exam request list after a SAR the institution filed late after a wire already left.
• Name the evaluation right federal banking exam-response lead would forfeit by rushing.
• For this US Federal Financial Crime and Sanctions file, read model-risk exam request list 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 federal banking exam-response lead.

Recommendation

Choose Improper payments are estimated / Actual on this US Federal / Financial Crime and Sanctions packet (model-risk exam request list after a SAR the institution filed late after a wire already left). The follow-on Financial Crime and Sanctions action is what federal banking exam-response lead does next: implement the option, assign an owner, and log the missing fact.