Assess whether comparative files show second-review bias (a450f7)

Situation

Geographic application and origination heat map arrived with a DOJ or CFPB monitor request for pricing files for model-risk partner for credit scoring. That is a Fair Lending CRA and Special-Purpose Programs decision on comparative files show second-review in a credit-card issuer changing line-assignment logic.

Decision

Model-risk partner for credit scoring in a credit-card issuer changing line-assignment logic must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using geographic application and origination heat map after a DOJ or CFPB monitor request for pricing files.

Hypotheses to test

• Authorize Remove access or reverse the item now; geographic application and origination heat map already has the discriminator after a DOJ or CFPB monitor request for pricing files.
• Keep Temporary compensating control in force until geographic application and origination heat map is completed after a DOJ or CFPB monitor request for pricing files for model-risk partner for credit scoring.
• Treat geographic application and origination heat map as Approve a documented exception because both readings appear after a DOJ or CFPB monitor request for pricing files.
• Refuse a Fair Lending close: model-risk partner for credit scoring does not have the page comparative files show second-review turns on in geographic application and origination heat map.

Analysis required

• Test a documented exception versus a pattern a credit-card issuer changing line-assignment logic must defend.
• Match the adverse-action language to the facts in geographic application and origination heat map.
• Check HMDA coding and underwriting policy against comparative files show second-review.
• For this Fair Lending CRA and Special-Purpose Programs file, read geographic application and origination heat map against a DOJ or CFPB monitor request for pricing files and write the one fact that would move comparative files show second-review for model-risk partner for credit scoring.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / CRA and Special-Purpose Programs packet (geographic application and origination heat map after a DOJ or CFPB monitor request for pricing files). Lead with the Fair Lending option geographic application and origination heat map can support after a DOJ or CFPB monitor request for pricing files, then the two facts that force it, then the Monday action for model-risk partner for credit scoring in a credit-card issuer changing line-assignment logic.