Assess whether dealer overlays introduce prohibited steering (6a9db2)

Situation

An underwriter chat that used coded language put SPCP written plan versus actual originations in front of model-risk partner for credit scoring in a credit-card issuer changing line-assignment logic. This Fair Lending / CRA and Special-Purpose Programs close is dealer overlays introduce prohibited from SPCP written plan versus actual originations, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

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 SPCP written plan versus actual originations after an underwriter chat that used coded language.

Hypotheses to test

• SPCP written plan versus actual originations reads as Remove access or reverse the item once an underwriter chat that used coded language is lined up to the same Fair Lending population.
• SPCP written plan versus actual originations is closer to Temporary compensating control after an underwriter chat that used coded language; Remove access or reverse the item would over-claim this CRA and Special-Purpose Programs extract.
• Approve a documented exception is still live in SPCP written plan versus actual originations for model-risk partner for credit scoring in a credit-card issuer changing line-assignment logic.
• SPCP written plan versus actual originations is missing the fact model-risk partner for credit scoring needs after an underwriter chat that used coded language; stop this Fair Lending close.

Analysis required

• Flag any disparate-impact table model-risk partner for credit scoring cannot explain from SPCP written plan versus actual originations.
• 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 SPCP written plan versus actual originations.
• For this Fair Lending CRA and Special-Purpose Programs file, read SPCP written plan versus actual originations against an underwriter chat that used coded language and write the one fact that would move dealer overlays introduce prohibited for model-risk partner for credit scoring.

Recommendation