Assess whether an OFAC match is true and requires blocking after an OCC

Situation

A bank in a fair-lending comparative-file exam cannot treat an OCC request for model validation of a fair-lending control as color commentary on Medicare billing-pattern outlier table. Federal banking exam-response lead must close an OFAC match is from that extract under US Federal / Financial Crime and Sanctions.

Decision

Federal banking exam-response lead in a bank in a fair-lending comparative-file exam must choose Pursue / Pursue with conditions / Partner / No-bid using Medicare billing-pattern outlier table after an OCC request for model validation of a fair-lending control.

Hypotheses to test

• The population in Medicare billing-pattern outlier table is the one an OCC request for model validation of a fair-lending control named, so Pursue follows for this Financial Crime and Sanctions file.
• The population in Medicare billing-pattern outlier table is adjacent only to an OCC request for model validation of a fair-lending control; Pursue with conditions is the honest US Federal call.
• A bank in a fair-lending comparative-file exam already contained an OCC request for model validation of a fair-lending control before Medicare billing-pattern outlier table arrived; no new Financial Crime and Sanctions path.
• Provenance on Medicare billing-pattern outlier table after an OCC request for model validation of a fair-lending control is broken; do not pick Pursue or Pursue with conditions yet.

Analysis required

• Map FAR, Section L/M, and evaluator priorities in Medicare billing-pattern outlier table after an OCC request for model validation of a fair-lending control.
• Name the evaluation right federal banking exam-response lead would forfeit by rushing.
• Normalize pricing and CPARS/QASP evidence that actually supports an OFAC match is.
• For this US Federal Financial Crime and Sanctions file, read Medicare billing-pattern outlier table against an OCC request for model validation of a fair-lending control and write the one fact that would move an OFAC match is for federal banking exam-response lead.

Recommendation

Choose Pursue / Pursue with conditions / Partner / No-bid on this US Federal / Financial Crime and Sanctions packet (Medicare billing-pattern outlier table after an OCC request for model validation of a fair-lending control). 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.