Assess whether dealer overlays introduce prohibited steering (6ea5f6)

SITUATION Model-risk partner for credit scoring in a small-business desk using a new vendor score has one working extract — HMDA LAR validity and quality edits — after a DOJ or CFPB monitor request for pricing files. If HMDA LAR validity and quality edits cannot support dealer overlays introduce prohibited, the only defensible Fair Lending output is hold.

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 HMDA LAR validity and quality edits after a DOJ or CFPB monitor request for pricing files.

HYPOTHESES TO TEST 1. HMDA LAR validity and quality edits reads as Remove access or reverse the item once a DOJ or CFPB monitor request for pricing files is lined up to the same Fair Lending population. 2. HMDA LAR validity and quality edits is closer to Temporary compensating control after a DOJ or CFPB monitor request for pricing files; Remove access or reverse the item would over-claim this Pricing and Credit Limits extract. 3. Approve a documented exception is still live in HMDA LAR validity and quality edits for model-risk partner for credit scoring in a small-business desk using a new vendor score. 4. HMDA LAR validity and quality edits is missing the fact model-risk partner for credit scoring needs after a DOJ or CFPB monitor request for pricing files; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Compare HMDA LAR validity and quality edits to similarly situated files, second-review notes, and reason codes after a DOJ or CFPB monitor request for pricing files. 2. Flag any disparate-impact table model-risk partner for credit scoring cannot explain from HMDA LAR validity and quality edits. 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 HMDA LAR validity and quality edits against a DOJ or CFPB monitor request for pricing files and write the one fact that would move dealer overlays introduce prohibited 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 (HMDA LAR validity and quality edits after a DOJ or CFPB monitor request for pricing files). Lead with the Fair Lending option HMDA LAR validity and quality edits can support after a DOJ or CFPB monitor request for pricing files, then the two facts that force it, then the Monday action for model-risk partner for credit scoring in a small-business desk using a new vendor score.