Assess whether a trial site should be referred (7076f1)

Situation

The desk packet is RFP Section L/M that omits a mandatory clause after an OCC request for model validation of a fair-lending control. Federal intrusion-response lead in a bank in a fair-lending comparative-file exam has to name Pursue or Pursue with conditions for this US Federal AI Governance Vendor Risk file.

Decision

Federal intrusion-response lead in a bank in a fair-lending comparative-file exam must choose Pursue / Pursue with conditions / Partner / No-bid using RFP Section L/M that omits a mandatory clause after an OCC request for model validation of a fair-lending control.

Hypotheses to test

• An OCC request for model validation of a fair-lending control is noise around an already-controlled AI Governance Vendor Risk process in a bank in a fair-lending comparative-file exam, given RFP Section L/M that omits a mandatory clause.
• An OCC request for model validation of a fair-lending control is the event in RFP Section L/M that omits a mandatory clause that forces Pursue for federal intrusion-response lead under US Federal.
• RFP Section L/M that omits a mandatory clause shows a one-file miss after an OCC request for model validation of a fair-lending control, not a AI Governance Vendor Risk program failure.
• RFP Section L/M that omits a mandatory clause cannot decide a trial site should be referred yet after an OCC request for model validation of a fair-lending control; hold is the only US Federal close a bank in a fair-lending comparative-file exam can defend.

Analysis required

• Normalize pricing and CPARS/QASP evidence that actually supports a trial site should be referred.
• Compare PTW and compliance gates in RFP Section L/M that omits a mandatory clause to a pursue / partner / no-bid split.
• Test OCI and SAM.gov status before a bank in a fair-lending comparative-file exam commits.
• For this US Federal AI Governance Vendor Risk file, read RFP Section L/M that omits a mandatory clause against an OCC request for model validation of a fair-lending control and write the one fact that would move a trial site should be referred for federal intrusion-response lead.

Recommendation

Choose Pursue / Pursue with conditions / Partner / No-bid on this US Federal / AI Governance Vendor Risk packet (RFP Section L/M that omits a mandatory clause after an OCC request for model validation of a fair-lending control). Lead with the US Federal option RFP Section L/M that omits a mandatory clause can support after an OCC request for model validation of a fair-lending control, then the two facts that force it, then the Monday action for federal intrusion-response lead in a bank in a fair-lending comparative-file exam.