Assess whether a model update needs a fair-lending revalidation (78fe8b)

Situation

Model-risk partner for credit scoring in a credit-card issuer changing line-assignment logic has one working extract — underwriting exception log by branch — after a notice that cites 'other' as the principal reason 40% of the time. Model-risk partner for credit scoring in a credit-card issuer changing line-assignment logic has underwriting exception log by branch after a notice that cites 'other' as the principal reason 40% of the time. If that extract cannot support a model update needs, the honest Fair Lending CRA and Special-Purpose Programs output is hold.

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 underwriting exception log by branch after a notice that cites 'other' as the principal reason 40% of the time.

Hypotheses to test

• The population in underwriting exception log by branch is the one a notice that cites 'other' as the principal reason 40% of the time named, so Remove access or reverse the item follows for this CRA and Special-Purpose Programs file.
• The population in underwriting exception log by branch is adjacent only to a notice that cites 'other' as the principal reason 40% of the time; Temporary compensating control is the honest Fair Lending call.
• A credit-card issuer changing line-assignment logic already contained a notice that cites 'other' as the principal reason 40% of the time before underwriting exception log by branch arrived; no new CRA and Special-Purpose Programs path.
• Provenance on underwriting exception log by branch after a notice that cites 'other' as the principal reason 40% of the time is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• 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.
• Check HMDA coding and underwriting policy against a model update needs.
• For this Fair Lending CRA and Special-Purpose Programs file, read underwriting exception log by branch against a notice that cites 'other' as the principal reason 40% of the time and write the one fact that would move a model update needs for model-risk partner for credit scoring.