The Exam Response Should Concede a Finding — Small-business Desk

Situation

Pricing and Credit Limits work in a small-business desk using a new vendor score now turns on the exam response should because a CRA PE that called the assessment area too narrow put CRA assessment-area versus lending footprint in play. Model-risk partner for credit scoring should say what CRA assessment-area versus lending footprint proves.

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 CRA assessment-area versus lending footprint after a CRA PE that called the assessment area too narrow.

Hypotheses to test

• Model-risk partner for credit scoring can defend Remove access or reverse the item from CRA assessment-area versus lending footprint after a CRA PE that called the assessment area too narrow in a Fair Lending challenge.
• Model-risk partner for credit scoring cannot defend Remove access or reverse the item from CRA assessment-area versus lending footprint; Temporary compensating control is what the extract actually supports after a CRA PE that called the assessment area too narrow.
• A CRA PE that called the assessment area too narrow never reached the population in CRA assessment-area versus lending footprint — reopen intake, do not close the exam response should.
• Two facts in CRA assessment-area versus lending footprint after a CRA PE that called the assessment area too narrow conflict for model-risk partner for credit scoring; hold this Pricing and Credit Limits file.

Analysis required

• Flag any disparate-impact table model-risk partner for credit scoring cannot explain from CRA assessment-area versus lending footprint.
• Test a documented exception versus a pattern a small-business desk using a new vendor score must defend.
• Match the adverse-action language to the facts in CRA assessment-area versus lending footprint.
• For this Fair Lending Pricing and Credit Limits file, read CRA assessment-area versus lending footprint against a CRA PE that called the assessment area too narrow and write the one fact that would move the exam response should 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 (CRA assessment-area versus lending footprint after a CRA PE that called the assessment area too narrow). If CRA assessment-area versus lending footprint cannot force a Fair Lending label under Pricing and Credit Limits, stop. Do not invent pages a small-business desk using a new vendor score does not have.