Assess whether pricing disparities are justified by legitimate factors

SITUATION A credit union rolling out a special-purpose credit program cannot treat a vendor score change with no disparate-impact test as incidental context on underwriting exception log by branch. Model-risk partner for credit scoring must close pricing disparities are justified from that extract under Fair Lending / Redlining and HMDA Data.

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 underwriting exception log by branch after a vendor score change with no disparate-impact test.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; underwriting exception log by branch already has the discriminator after a vendor score change with no disparate-impact test. 2. Keep Temporary compensating control in force until underwriting exception log by branch is completed after a vendor score change with no disparate-impact test for model-risk partner for credit scoring. 3. Treat underwriting exception log by branch as Approve a documented exception because both readings appear after a vendor score change with no disparate-impact test. 4. Refuse a Fair Lending close: model-risk partner for credit scoring does not have the decision pricing disparities are justified turns on in underwriting exception log by branch.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against pricing disparities are justified. 2. Compare underwriting exception log by branch to similarly situated files, second-review notes, and reason codes after a vendor score change with no disparate-impact test. 3. Flag any disparate-impact table model-risk partner for credit scoring cannot explain from underwriting exception log by branch. 4. For this Fair Lending Redlining and HMDA Data file, read underwriting exception log by branch against a vendor score change with no disparate-impact test and write the one fact that would move pricing disparities are justified 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 (underwriting exception log by branch after a vendor score change with no disparate-impact test). Lead with the Fair Lending option underwriting exception log by branch can support after a vendor score change with no disparate-impact test, then the two facts that force it, then the Monday action for model-risk partner for credit scoring in a credit union rolling out a special-purpose credit program.