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

SITUATION A notice that cites 'other' as the principal reason 40% of the time put adverse-action notice principal-reason sample in front of model-risk partner for credit scoring in a credit union rolling out a special-purpose credit program. This Fair Lending / Redlining and HMDA Data close is line assignments have a from adverse-action notice principal-reason sample, 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 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 adverse-action notice principal-reason sample after a notice that cites 'other' as the principal reason 40% of the time.

HYPOTHESES TO TEST 1. Adverse-action notice principal-reason sample reads as Remove access or reverse the item once a notice that cites 'other' as the principal reason 40% of the time is lined up to the same Fair Lending population. 2. Adverse-action notice principal-reason sample is closer to Temporary compensating control after a notice that cites 'other' as the principal reason 40% of the time; Remove access or reverse the item would over-claim this Redlining and HMDA Data extract. 3. Approve a documented exception is still live in adverse-action notice principal-reason sample for model-risk partner for credit scoring in a credit union rolling out a special-purpose credit program. 4. Adverse-action notice principal-reason sample is missing the fact model-risk partner for credit scoring needs after a notice that cites 'other' as the principal reason 40% of the time; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Compare adverse-action notice principal-reason sample to similarly situated files, second-review notes, and reason codes after a notice that cites 'other' as the principal reason 40% of the time. 2. Flag any disparate-impact table model-risk partner for credit scoring cannot explain from adverse-action notice principal-reason sample. 3. Test a documented exception versus a pattern a credit union rolling out a special-purpose credit program must defend. 4. For this Fair Lending Redlining and HMDA Data file, read adverse-action notice principal-reason sample against a notice that cites 'other' as the principal reason 40% of the time 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 (adverse-action notice principal-reason sample after a notice that cites 'other' as the principal reason 40% of the time). If adverse-action notice principal-reason sample cannot force a Fair Lending label under Redlining and HMDA Data, stop. If adverse-action notice principal-reason sample after a notice that cites 'other' as the principal reason 40% of the time cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending Redlining and HMDA Data close, model-risk partner for credit scoring must do not infer a control or scheme beyond the transaction and entitlement evidence.