Assess whether dealer overlays introduce prohibited steering (3b3bfd)

Situation

Model-risk partner for credit scoring in a credit-card issuer changing line-assignment logic has one working extract — small-business decline comparative file set — after an underwriter chat that used coded language. Model-risk partner for credit scoring in a credit-card issuer changing line-assignment logic has small-business decline comparative file set after an underwriter chat that used coded language. If that extract cannot support dealer overlays introduce prohibited, the honest Fair Lending CRA and Special-Purpose Programs output is hold.

Decision

Model-risk partner for credit scoring 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 small-business decline comparative file set after an underwriter chat that used coded language.

Hypotheses to test

• The population in small-business decline comparative file set is the one an underwriter chat that used coded language named, so Remove access or reverse the item follows for this CRA and Special-Purpose Programs file.
• The population in small-business decline comparative file set is adjacent only to an underwriter chat that used coded language; Temporary compensating control is the honest Fair Lending call.
• A credit-card issuer changing line-assignment logic already contained an underwriter chat that used coded language before small-business decline comparative file set arrived; no new CRA and Special-Purpose Programs path.
• Provenance on small-business decline comparative file set after an underwriter chat that used coded language is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Test a documented exception versus a pattern a credit-card issuer changing line-assignment logic must defend.
• Match the adverse-action language to the facts in small-business decline comparative file set.
• Check HMDA coding and underwriting policy against dealer overlays introduce prohibited.
• For this Fair Lending CRA and Special-Purpose Programs file, read small-business decline comparative file set against an underwriter chat that used coded language and write the one fact that would move dealer overlays introduce prohibited for model-risk partner for credit scoring.