Assess whether a model update needs a fair-lending revalidation (b9c9ee)

Situation

Second-review underwriter in a credit-card issuer changing line-assignment logic has one working extract — mortgage pricing residual by prohibited-basis group — after an underwriter chat that used coded language. If mortgage pricing residual by prohibited-basis group cannot support a model update needs, the honest Fair Lending output is hold.

Decision

Second-review underwriter in a credit-card issuer changing line-assignment logic must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using mortgage pricing residual by prohibited-basis group after an underwriter chat that used coded language.

Hypotheses to test

• An underwriter chat that used coded language is noise around an already-controlled Pricing and Credit Limits process in a credit-card issuer changing line-assignment logic, given mortgage pricing residual by prohibited-basis group.
• An underwriter chat that used coded language is the event in mortgage pricing residual by prohibited-basis group that forces Remove access or reverse the item for second-review underwriter under Fair Lending.
• Mortgage pricing residual by prohibited-basis group shows a one-file miss after an underwriter chat that used coded language, not a Pricing and Credit Limits program failure.
• Mortgage pricing residual by prohibited-basis group cannot decide a model update needs yet after an underwriter chat that used coded language; hold is the only Fair Lending close a credit-card issuer changing line-assignment logic can defend.

Analysis required

• Compare mortgage pricing residual by prohibited-basis group to similarly situated files, second-review notes, and reason codes after an underwriter chat that used coded language.
• Flag any disparate-impact table second-review underwriter cannot explain from mortgage pricing residual by prohibited-basis group.
• Test a documented exception versus a pattern a credit-card issuer changing line-assignment logic must defend.
• For this Fair Lending Pricing and Credit Limits file, read mortgage pricing residual by prohibited-basis group against an underwriter chat that used coded language and write the one fact that would move a model update needs for second-review underwriter.

Recommendation