Assess whether comparative files show second-review bias (d1afb2)

SITUATION A small-business desk using a new vendor score cannot treat a community complaint about appraisal gaps as incidental context on SPCP written plan versus actual originations. Model-risk partner for credit scoring must close comparative files show second-review from that extract under Fair Lending / Pricing and Credit Limits.

DECISION Model-risk partner for credit scoring in a small-business desk using a new vendor score must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using SPCP written plan versus actual originations after a community complaint about appraisal gaps.

HYPOTHESES TO TEST 1. SPCP written plan versus actual originations reads as Remove access or reverse the item once a community complaint about appraisal gaps is lined up to the same Fair Lending population. 2. SPCP written plan versus actual originations is closer to Temporary compensating control after a community complaint about appraisal gaps; Remove access or reverse the item would over-claim this Pricing and Credit Limits extract. 3. Approve a documented exception is still live in SPCP written plan versus actual originations for model-risk partner for credit scoring in a small-business desk using a new vendor score. 4. SPCP written plan versus actual originations is missing the fact model-risk partner for credit scoring needs after a community complaint about appraisal gaps; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Compare SPCP written plan versus actual originations to similarly situated files, second-review notes, and reason codes after a community complaint about appraisal gaps. 2. Flag any disparate-impact table model-risk partner for credit scoring cannot explain from SPCP written plan versus actual originations. 3. Test a documented exception versus a pattern a small-business desk using a new vendor score must defend. 4. For this Fair Lending Pricing and Credit Limits file, read SPCP written plan versus actual originations against a community complaint about appraisal gaps and write the one fact that would move comparative files show second-review 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 / Pricing and Credit Limits packet (SPCP written plan versus actual originations after a community complaint about appraisal gaps). If SPCP written plan versus actual originations 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.