Assess whether line assignments have a disparate impact the bank will defend

SITUATION Small-business decline comparative file set arrived with a vendor score change with no disparate-impact test for adverse-action notice operations lead. That is a Fair Lending Pricing and Credit Limits decision on line assignments have a in a credit union rolling out a special-purpose credit program.

DECISION Adverse-action notice operations lead 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 small-business decline comparative file set after a vendor score change with no disparate-impact test.

HYPOTHESES TO TEST 1. Small-business decline comparative file set reads as Remove access or reverse the item once a vendor score change with no disparate-impact test is lined up to the same Fair Lending population. 2. Small-business decline comparative file set is closer to Temporary compensating control after a vendor score change with no disparate-impact test; Remove access or reverse the item would over-claim this Pricing and Credit Limits extract. 3. Approve a documented exception is still live in small-business decline comparative file set for adverse-action notice operations lead in a credit union rolling out a special-purpose credit program. 4. Small-business decline comparative file set is missing the fact adverse-action notice operations lead needs after a vendor score change with no disparate-impact test; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern a credit union rolling out a special-purpose credit program must defend. 2. Match the adverse-action language to the facts in small-business decline comparative file set. 3. Check HMDA coding and underwriting policy against line assignments have a. 4. For this Fair Lending Pricing and Credit Limits file, read small-business decline comparative file set against a vendor score change with no disparate-impact test and write the one fact that would move line assignments have a for adverse-action notice operations lead.

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 (small-business decline comparative file set after a vendor score change with no disparate-impact test). The follow-on Pricing and Credit Limits action is what adverse-action notice operations lead does next: implement the option, assign an owner, and log the missing fact.

COMMAND RETURNS - Bottom-line Fair Lending option on line assignments have a, then the evidence in small-business decline comparative file set, then the action for adverse-action notice operations lead - Hypothesis scorecard against small-business decline comparative file set: supported / rejected / untestable - Pricing and Credit Limits finding in small-business decline comparative file set that a second reviewer can re-perform - Missing page in small-business decline comparative file set after a vendor score change with no disparate-impact test, if any