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

SITUATION After a vendor score change with no disparate-impact test, HMDA LAR validity and quality edits is what model-risk partner for credit scoring can touch in a credit-card issuer changing line-assignment logic. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this CRA and Special-Purpose Programs file.

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 HMDA LAR validity and quality edits after a vendor score change with no disparate-impact test.

HYPOTHESES TO TEST 1. HMDA LAR validity and quality edits reads as Remove access or reverse the item once a vendor score change with no disparate-impact test is lined up to the same Fair Lending population. 2. HMDA LAR validity and quality edits is closer to Temporary compensating control after a vendor score change with no disparate-impact test; Remove access or reverse the item would over-claim this CRA and Special-Purpose Programs extract. 3. Approve a documented exception is still live in HMDA LAR validity and quality edits for model-risk partner for credit scoring in a credit-card issuer changing line-assignment logic. 4. HMDA LAR validity and quality edits is missing the fact model-risk partner for credit scoring needs after a vendor score change with no disparate-impact test; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Compare HMDA LAR validity and quality edits to similarly situated files, second-review notes, and reason codes after a vendor score change with no disparate-impact test. 2. Flag any disparate-impact table model-risk partner for credit scoring cannot explain from HMDA LAR validity and quality edits. 3. Test a documented exception versus a pattern a credit-card issuer changing line-assignment logic must defend. 4. For this Fair Lending CRA and Special-Purpose Programs file, read HMDA LAR validity and quality edits against a vendor score change with no disparate-impact test 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 / CRA and Special-Purpose Programs packet (HMDA LAR validity and quality edits after a vendor score change with no disparate-impact test). The follow-on CRA and Special-Purpose Programs action is what model-risk partner for credit scoring does next: implement the option, assign an owner, and log the missing fact.