Assess whether pricing disparities are justified by legitimate factors

SITUATION A lender expanding into majority-minority census tracts cannot treat a branch that stopped taking applications in one ZIP as incidental context on model-reason-code mapping that does not match notices. Model-risk partner for credit scoring must close pricing disparities are justified from that extract under Fair Lending / Examination and Notices.

DECISION Model-risk partner for credit scoring in a lender expanding into majority-minority census tracts 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 branch that stopped taking applications in one ZIP.

HYPOTHESES TO TEST 1. A branch that stopped taking applications in one ZIP is noise around an already-controlled Examination and Notices process in a lender expanding into majority-minority census tracts, given model-reason-code mapping that does not match notices. 2. A branch that stopped taking applications in one ZIP 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 branch that stopped taking applications in one ZIP, not a Examination and Notices program failure. 4. Model-reason-code mapping that does not match notices cannot decide pricing disparities are justified yet after a branch that stopped taking applications in one ZIP; hold is the only Fair Lending close a lender expanding into majority-minority census tracts can defend.

ANALYSIS REQUIRED 1. Compare model-reason-code mapping that does not match notices to similarly situated files, second-review notes, and reason codes after a branch that stopped taking applications in one ZIP. 2. Flag any disparate-impact table model-risk partner for credit scoring cannot explain from model-reason-code mapping that does not match notices. 3. Test a documented exception versus a pattern a lender expanding into majority-minority census tracts must defend. 4. For this Fair Lending Examination and Notices file, read model-reason-code mapping that does not match notices against a branch that stopped taking applications in one ZIP 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 / Examination and Notices packet (model-reason-code mapping that does not match notices after a branch that stopped taking applications in one ZIP). If model-reason-code mapping that does not match notices cannot force a Fair Lending label under Examination and Notices, stop. Do not invent missing evidence a lender expanding into majority-minority census tracts does not have.