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

SITUATION Model-reason-code mapping that does not match notices arrived with a SPCP that originated almost no loans to the intended class for model-risk partner for credit scoring. That is a Fair Lending Redlining and HMDA Data decision on line assignments have a in a credit union rolling out a special-purpose credit program.

DECISION Model-risk partner for credit scoring in a credit union rolling out a special-purpose credit program must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using model-reason-code mapping that does not match notices after a SPCP that originated almost no loans to the intended class.

HYPOTHESES TO TEST 1. A SPCP that originated almost no loans to the intended class is noise around an already-controlled Redlining and HMDA Data process in a credit union rolling out a special-purpose credit program, given model-reason-code mapping that does not match notices. 2. A SPCP that originated almost no loans to the intended class is the event in model-reason-code mapping that does not match notices that forces Remove access or reverse the item for model-risk partner for credit scoring under Fair Lending. 3. Model-reason-code mapping that does not match notices shows a one-file miss after a SPCP that originated almost no loans to the intended class, not a Redlining and HMDA Data program failure. 4. Model-reason-code mapping that does not match notices cannot decide line assignments have a yet after a SPCP that originated almost no loans to the intended class; hold is the only Fair Lending close a credit union rolling out a special-purpose credit program can defend.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against line assignments have a. 2. Compare model-reason-code mapping that does not match notices 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 model-reason-code mapping that does not match notices. 4. For this Fair Lending Redlining and HMDA Data file, read model-reason-code mapping that does not match notices 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 / Redlining and HMDA Data packet (model-reason-code mapping that does not match notices after a SPCP that originated almost no loans to the intended class). The follow-on Redlining and HMDA Data action is what model-risk partner for credit scoring does next: implement the option, assign an owner, and log the missing fact.