Assess whether line assignments have a disparate impact the bank will defend

SITUATION In a small-business desk using a new vendor score, credit-card limit assignment disparity table 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 Pricing and Credit Limits close using credit-card limit assignment disparity table.

DECISION Model-risk partner for credit scoring in a small-business desk using a new vendor score must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using credit-card limit assignment disparity table after a branch that stopped taking applications in one ZIP.

HYPOTHESES TO TEST 1. Model-risk partner for credit scoring can defend Remove access or reverse the item from credit-card limit assignment disparity table after a branch that stopped taking applications in one ZIP in a Fair Lending challenge. 2. Model-risk partner for credit scoring cannot defend Remove access or reverse the item from credit-card limit assignment disparity table; Temporary compensating control is what the extract actually supports after a branch that stopped taking applications in one ZIP. 3. A branch that stopped taking applications in one ZIP never reached the population in credit-card limit assignment disparity table — reopen intake, do not close line assignments have a. 4. Two facts in credit-card limit assignment disparity table after a branch that stopped taking applications in one ZIP conflict for model-risk partner for credit scoring; hold this Pricing and Credit Limits file.

ANALYSIS REQUIRED 1. Flag any disparate-impact table model-risk partner for credit scoring cannot explain from credit-card limit assignment disparity table. 2. Test a documented exception versus a pattern a small-business desk using a new vendor score must defend. 3. Match the adverse-action language to the facts in credit-card limit assignment disparity table. 4. For this Fair Lending Pricing and Credit Limits file, read credit-card limit assignment disparity table against a branch that stopped taking applications in one ZIP and write the one fact that would move line assignments have a 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 / Pricing and Credit Limits packet (credit-card limit assignment disparity table after a branch that stopped taking applications in one ZIP). If credit-card limit assignment disparity table cannot force a Fair Lending label under Pricing and Credit Limits, stop. Do not invent missing evidence a small-business desk using a new vendor score does not have.