Assess whether a special-purpose program is well designed or a pretext

Situation

After a marketing mailer that skipped majority-minority tracts, credit-card limit assignment disparity table is what model-risk partner for credit scoring can touch in a credit-card issuer changing line-assignment logic. Fair Lending will live with A special-purpose program is well designed versus A pretext 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 A special-purpose program is well designed / A pretext using credit-card limit assignment disparity table after a marketing mailer that skipped majority-minority tracts.

Hypotheses to test

• Authorize A special-purpose program is well designed now; credit-card limit assignment disparity table already has the discriminator after a marketing mailer that skipped majority-minority tracts.
• Keep A pretext in force until credit-card limit assignment disparity table is completed after a marketing mailer that skipped majority-minority tracts for model-risk partner for credit scoring.
• Treat credit-card limit assignment disparity table as A special-purpose program is well designed because both readings appear after a marketing mailer that skipped majority-minority tracts.
• Refuse a Fair Lending close: model-risk partner for credit scoring does not have the page a special-purpose program is turns on in credit-card limit assignment disparity table.

Analysis required

• Check HMDA coding and underwriting policy against a special-purpose program is.
• Compare credit-card limit assignment disparity table to similarly situated files, second-review notes, and reason codes after a marketing mailer that skipped majority-minority tracts.
• Flag any disparate-impact table model-risk partner for credit scoring cannot explain from credit-card limit assignment disparity table.
• For this Fair Lending CRA and Special-Purpose Programs file, read credit-card limit assignment disparity table against a marketing mailer that skipped majority-minority tracts and write the one fact that would move a special-purpose program is for model-risk partner for credit scoring.

Recommendation

Choose A special-purpose program is well designed / A pretext on this Fair Lending / CRA and Special-Purpose Programs packet (credit-card limit assignment disparity table after a marketing mailer that skipped majority-minority tracts). 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.