Assess whether the exam response should concede a finding (ef2ec2)

SITUATION CRA assessment-area versus lending footprint arrived with a vendor score change with no disparate-impact test. Model-risk partner for credit scoring in a credit union rolling out a special-purpose credit program still has an evidence gap on whether the exam response should concede a finding.

DECISION Model-risk partner for credit scoring in a credit union rolling out a special-purpose credit program 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 vendor score change with no disparate-impact test.

HYPOTHESES TO TEST 1. A vendor score change with no disparate-impact test is noise around an already-controlled Redlining and HMDA Data process in a credit union rolling out a special-purpose credit program, given CRA assessment-area versus lending footprint. 2. A vendor score change with no disparate-impact test is the event in CRA assessment-area versus lending footprint that forces Remove access or reverse the item for model-risk partner for credit scoring under Fair Lending. 3. CRA assessment-area versus lending footprint shows a one-file miss after a vendor score change with no disparate-impact test, not a Redlining and HMDA Data program failure. 4. CRA assessment-area versus lending footprint cannot decide the exam response should yet after a vendor score change with no disparate-impact test; hold is the only Fair Lending close a credit union rolling out a special-purpose credit program can defend.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in CRA assessment-area versus lending footprint. 2. Check HMDA coding and underwriting policy against the exam response should. 3. Compare CRA assessment-area versus lending footprint to similarly situated files, second-review notes, and reason codes after a vendor score change with no disparate-impact test. 4. For this Fair Lending Redlining and HMDA Data file, read CRA assessment-area versus lending footprint against a vendor score change with no disparate-impact test 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 / Redlining and HMDA Data packet (CRA assessment-area versus lending footprint after a vendor score change with no disparate-impact test). Lead with the Fair Lending option CRA assessment-area versus lending footprint can support after a vendor score change with no disparate-impact test, then the two facts that force it, then the Monday action for model-risk partner for credit scoring in a credit union rolling out a special-purpose credit program.