Assess whether threshold splitting is a procurement-integrity issue (1f8f04)

Situation

An OCC request for model validation of a fair-lending control put purchase-request split just under the SAT in front of federal AI-procurement reviewer in a financial institution responding to a FinCEN inquiry. This US Federal / AI Governance Vendor Risk close is threshold splitting is a from purchase-request split just under the SAT, and the live options are Pursue, Pursue with conditions, Partner.

Decision

Federal AI-procurement reviewer in a financial institution responding to a FinCEN inquiry must choose Pursue / Pursue with conditions / Partner / No-bid using purchase-request split just under the SAT after an OCC request for model validation of a fair-lending control.

Hypotheses to test

• The population in purchase-request split just under the SAT is the one an OCC request for model validation of a fair-lending control named, so Pursue follows for this AI Governance Vendor Risk file.
• The population in purchase-request split just under the SAT 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 financial institution responding to a FinCEN inquiry already contained an OCC request for model validation of a fair-lending control before purchase-request split just under the SAT arrived; no new AI Governance Vendor Risk path.
• Provenance on purchase-request split just under the SAT 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

• Compare PTW and compliance gates in purchase-request split just under the SAT to a pursue / partner / no-bid split.
• Test OCI and SAM.gov status before a financial institution responding to a FinCEN inquiry commits.
• Map FAR, Section L/M, and evaluator priorities in purchase-request split just under the SAT after an OCC request for model validation of a fair-lending control.
• For this US Federal AI Governance Vendor Risk file, read purchase-request split just under the SAT against an OCC request for model validation of a fair-lending control and write the one fact that would move threshold splitting is a for federal AI-procurement reviewer.

Recommendation

Choose Pursue / Pursue with conditions / Partner / No-bid on this US Federal / AI Governance Vendor Risk packet (purchase-request split just under the SAT after an OCC request for model validation of a fair-lending control). The follow-on AI Governance Vendor Risk action is what federal AI-procurement reviewer does next: implement the option, assign an owner, and log the missing fact.