Assess whether the exam response should concede a finding (fc0452)

SITUATION A credit-card issuer changing line-assignment logic has mortgage pricing residual by prohibited-basis group in hand following a CRA PE that called the assessment area too narrow. Model-risk partner for credit scoring must determine whether the exam response should concede a finding for this Fair Lending CRA and Special-Purpose Programs file.

DECISION Model-risk partner for credit scoring in a credit-card issuer changing line-assignment logic must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using mortgage pricing residual by prohibited-basis group after a CRA PE that called the assessment area too narrow.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; mortgage pricing residual by prohibited-basis group already has the discriminator after a CRA PE that called the assessment area too narrow. 2. Keep Temporary compensating control in force until mortgage pricing residual by prohibited-basis group is completed after a CRA PE that called the assessment area too narrow for model-risk partner for credit scoring. 3. Treat mortgage pricing residual by prohibited-basis group as Approve a documented exception because both readings appear after a CRA PE that called the assessment area too narrow. 4. Refuse a Fair Lending close: model-risk partner for credit scoring does not have the decision the exam response should turns on in mortgage pricing residual by prohibited-basis group.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against the exam response should. 2. Compare mortgage pricing residual by prohibited-basis group to similarly situated files, second-review notes, and reason codes after a CRA PE that called the assessment area too narrow. 3. Flag any disparate-impact table model-risk partner for credit scoring cannot explain from mortgage pricing residual by prohibited-basis group. 4. For this Fair Lending CRA and Special-Purpose Programs file, read mortgage pricing residual by prohibited-basis group 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 / CRA and Special-Purpose Programs packet (mortgage pricing residual by prohibited-basis group after a CRA PE that called the assessment area too narrow). Lead with the Fair Lending option mortgage pricing residual by prohibited-basis group can support after a CRA PE that called the assessment area too narrow, then the two facts that force it, then the Monday action for model-risk partner for credit scoring in a credit-card issuer changing line-assignment logic.