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

SITUATION The working file is HMDA LAR validity and quality edits after a SPCP that originated almost no loans to the intended class. Model-risk partner for credit scoring in a small-business desk using a new vendor score has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending Pricing and Credit Limits file.

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 HMDA LAR validity and quality edits after a SPCP that originated almost no loans to the intended class.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; HMDA LAR validity and quality edits already has the discriminator after a SPCP that originated almost no loans to the intended class. 2. Keep Temporary compensating control in force until HMDA LAR validity and quality edits is completed after a SPCP that originated almost no loans to the intended class for model-risk partner for credit scoring. 3. Treat HMDA LAR validity and quality edits as Approve a documented exception because both readings appear after a SPCP that originated almost no loans to the intended class. 4. Refuse a Fair Lending close: model-risk partner for credit scoring does not have the decision line assignments have a turns on in HMDA LAR validity and quality edits.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against line assignments have a. 2. Compare HMDA LAR validity and quality edits to similarly situated files, second-review notes, and reason codes after a SPCP that originated almost no loans to the intended class. 3. Flag any disparate-impact table model-risk partner for credit scoring cannot explain from HMDA LAR validity and quality edits. 4. For this Fair Lending Pricing and Credit Limits file, read HMDA LAR validity and quality edits against a SPCP that originated almost no loans to the intended class 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 (HMDA LAR validity and quality edits after a SPCP that originated almost no loans to the intended class). If HMDA LAR validity and quality edits 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.

COMMAND RETURNS - Bottom-line Fair Lending option on line assignments have a, then the evidence in HMDA LAR validity and quality edits, then the action for model-risk partner for credit scoring - Hypothesis scorecard against HMDA LAR validity and quality edits: supported / rejected / untestable - Missing page in HMDA LAR validity and quality edits after a SPCP that originated almost no loans to the intended class, if any - Regulatory or exam hook Pricing and Credit Limits would cite