Assess whether a model update needs a fair-lending revalidation (4c81fc)

Situation

Adverse-action notice operations lead in a credit-card issuer changing line-assignment logic has one working extract — underwriting exception log by branch — after a board asking if the bank should settle a matched-pair study. If underwriting exception log by branch cannot support a model update needs, the honest Fair Lending output is hold.

Decision

Adverse-action notice operations lead 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 underwriting exception log by branch after a board asking if the bank should settle a matched-pair study.

Hypotheses to test

• Underwriting exception log by branch reads as Remove access or reverse the item once a board asking if the bank should settle a matched-pair study is lined up to the same Fair Lending population.
• Underwriting exception log by branch is closer to Temporary compensating control after a board asking if the bank should settle a matched-pair study; Remove access or reverse the item would over-claim this Examination and Notices extract.
• Approve a documented exception is still live in underwriting exception log by branch for adverse-action notice operations lead in a credit-card issuer changing line-assignment logic.
• Underwriting exception log by branch is missing the fact adverse-action notice operations lead needs after a board asking if the bank should settle a matched-pair study; stop this Fair Lending close.

Analysis required

• Flag any disparate-impact table adverse-action notice operations lead cannot explain from underwriting exception log by branch.
• Test a documented exception versus a pattern a credit-card issuer changing line-assignment logic must defend.
• Match the adverse-action language to the facts in underwriting exception log by branch.
• For this Fair Lending Examination and Notices file, read underwriting exception log by branch against a board asking if the bank should settle a matched-pair study and write the one fact that would move a model update needs 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 / Examination and Notices packet (underwriting exception log by branch after a board asking if the bank should settle a matched-pair study). The follow-on Examination and Notices action is what adverse-action notice operations lead does next: implement the option, assign an owner, and log the missing fact.