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

SITUATION After a board asking if the bank should settle a matched-pair study, small-business decline comparative file set is what model-risk partner for credit scoring can touch in a small-business desk using a new vendor score. Fair Lending will live with A special-purpose program is well designed versus A pretext on this Pricing and Credit Limits file.

DECISION Model-risk partner for credit scoring in a small-business desk using a new vendor score must choose A special-purpose program is well designed / A pretext using small-business decline comparative file set after a board asking if the bank should settle a matched-pair study.

HYPOTHESES TO TEST 1. A board asking if the bank should settle a matched-pair study is noise around an already-controlled Pricing and Credit Limits process in a small-business desk using a new vendor score, given small-business decline comparative file set. 2. A board asking if the bank should settle a matched-pair study is the event in small-business decline comparative file set that forces A special-purpose program is well designed for model-risk partner for credit scoring under Fair Lending. 3. Small-business decline comparative file set shows a one-file miss after a board asking if the bank should settle a matched-pair study, not a Pricing and Credit Limits program failure. 4. Small-business decline comparative file set cannot decide a special-purpose program is yet after a board asking if the bank should settle a matched-pair study; hold is the only Fair Lending close a small-business desk using a new vendor score can defend.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against a special-purpose program is. 2. Compare small-business decline comparative file set to similarly situated files, second-review notes, and reason codes after a board asking if the bank should settle a matched-pair study. 3. Flag any disparate-impact table model-risk partner for credit scoring cannot explain from small-business decline comparative file set. 4. For this Fair Lending Pricing and Credit Limits file, read small-business decline comparative file set against a board asking if the bank should settle a matched-pair study 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 / Pricing and Credit Limits packet (small-business decline comparative file set after a board asking if the bank should settle a matched-pair study). If small-business decline comparative file set cannot force a Fair Lending label under Pricing and Credit Limits, stop. Do not invent missing evidence a small-business desk using a new vendor score does not have.