Assess whether notices match the actual decisioning reasons (53cd88)

SITUATION The working file is underwriting exception log by branch after a vendor score change with no disparate-impact test. Model-risk partner for credit scoring in a lender expanding into majority-minority census tracts has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending 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 underwriting exception log by branch after a vendor score change with no disparate-impact test.

HYPOTHESES TO TEST 1. Underwriting exception log by branch 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. Underwriting exception log by branch 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 Examination and Notices extract. 3. Approve a documented exception is still live in underwriting exception log by branch for model-risk partner for credit scoring in a lender expanding into majority-minority census tracts. 4. Underwriting exception log by branch is missing the fact model-risk partner for credit scoring needs after a vendor score change with no disparate-impact test; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Compare underwriting exception log by branch to similarly situated files, second-review notes, and reason codes after a vendor score change with no disparate-impact test. 2. Flag any disparate-impact table model-risk partner for credit scoring cannot explain from underwriting exception log by branch. 3. Test a documented exception versus a pattern a lender expanding into majority-minority census tracts must defend. 4. For this Fair Lending Examination and Notices file, read underwriting exception log by branch against a vendor score change with no disparate-impact test and write the one fact that would move notices match the actual 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 (underwriting exception log by branch after a vendor score change with no disparate-impact test). Lead with the Fair Lending option underwriting exception log by branch can support after a vendor score change with no disparate-impact test, then the two facts that force it, then the Monday action for model-risk partner for credit scoring in a lender expanding into majority-minority census tracts.