Assess whether dealer overlays introduce prohibited steering (ed2e1a)

Situation

In a credit-card issuer changing line-assignment logic, geographic application and origination heat map is the evidence after a branch that stopped taking applications in one ZIP. Model-risk partner for credit scoring has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending CRA and Special-Purpose Programs close using geographic application and origination heat map.

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 branch that stopped taking applications in one ZIP.

Hypotheses to test

• Geographic application and origination heat map reads as Remove access or reverse the item once a branch that stopped taking applications in one ZIP is lined up to the same Fair Lending population.
• Geographic application and origination heat map is closer to Temporary compensating control after a branch that stopped taking applications in one ZIP; Remove access or reverse the item would over-claim this CRA and Special-Purpose Programs extract.
• Approve a documented exception is still live in geographic application and origination heat map for model-risk partner for credit scoring in a credit-card issuer changing line-assignment logic.
• Geographic application and origination heat map is missing the fact model-risk partner for credit scoring needs after a branch that stopped taking applications in one ZIP; stop this Fair Lending close.

Analysis required

• Compare geographic application and origination heat map to similarly situated files, second-review notes, and reason codes after a branch that stopped taking applications in one ZIP.
• Flag any disparate-impact table model-risk partner for credit scoring cannot explain from geographic application and origination heat map.
• Test a documented exception versus a pattern a credit-card issuer changing line-assignment logic must defend.
• For this Fair Lending CRA and Special-Purpose Programs file, read geographic application and origination heat map against a branch that stopped taking applications in one ZIP and write the one fact that would move dealer overlays introduce prohibited for model-risk partner for credit scoring.