Assess whether the exam response should concede a finding (75c4f2)

SITUATION After a DOJ or CFPB monitor request for pricing files, model-reason-code mapping that does not match notices is what model-risk partner for credit scoring can touch in a lender expanding into majority-minority census tracts. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this Examination and Notices file.

DECISION Model-risk partner for credit scoring in a lender expanding into majority-minority census tracts must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using model-reason-code mapping that does not match notices after a DOJ or CFPB monitor request for pricing files.

HYPOTHESES TO TEST 1. The population in model-reason-code mapping that does not match notices is the one a DOJ or CFPB monitor request for pricing files named, so Remove access or reverse the item follows for this Examination and Notices file. 2. The population in model-reason-code mapping that does not match notices is adjacent only to a DOJ or CFPB monitor request for pricing files; Temporary compensating control is the honest Fair Lending call. 3. A lender expanding into majority-minority census tracts already contained a DOJ or CFPB monitor request for pricing files before model-reason-code mapping that does not match notices arrived; no new Examination and Notices path. 4. Provenance on model-reason-code mapping that does not match notices after a DOJ or CFPB monitor request for pricing files is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in model-reason-code mapping that does not match notices. 2. Check HMDA coding and underwriting policy against the exam response should. 3. Compare model-reason-code mapping that does not match notices to similarly situated files, second-review notes, and reason codes after a DOJ or CFPB monitor request for pricing files. 4. For this Fair Lending Examination and Notices file, read model-reason-code mapping that does not match notices against a DOJ or CFPB monitor request for pricing files 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 / Examination and Notices packet (model-reason-code mapping that does not match notices after a DOJ or CFPB monitor request for pricing files). The follow-on Examination and Notices action is what model-risk partner for credit scoring does next: implement the option, assign an owner, and log the missing fact.