Assess whether a redlining pattern exists after controls (45c6f4)

Situation

Model-risk partner for credit scoring owns a redlining pattern exists inside a credit union rolling out a special-purpose credit program with CRA assessment-area versus lending footprint as the only packet. An exception rate twice as high for one group after credit controls is what changed the clock for this Fair Lending Redlining and HMDA Data file.

Decision

Model-risk partner for credit scoring 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 CRA assessment-area versus lending footprint after an exception rate twice as high for one group after credit controls.

Hypotheses to test

• CRA assessment-area versus lending footprint reads as Remove access or reverse the item once an exception rate twice as high for one group after credit controls is lined up to the same Fair Lending population.
• CRA assessment-area versus lending footprint is closer to Temporary compensating control after an exception rate twice as high for one group after credit controls; Remove access or reverse the item would over-claim this Redlining and HMDA Data extract.
• Approve a documented exception is still live in CRA assessment-area versus lending footprint for model-risk partner for credit scoring in a credit union rolling out a special-purpose credit program.
• CRA assessment-area versus lending footprint is missing the fact model-risk partner for credit scoring needs after an exception rate twice as high for one group after credit controls; stop this Fair Lending close.

Analysis required

• Flag any disparate-impact table model-risk partner for credit scoring cannot explain from CRA assessment-area versus lending footprint.
• Test a documented exception versus a pattern a credit union rolling out a special-purpose credit program must defend.
• Match the adverse-action language to the facts in CRA assessment-area versus lending footprint.
• For this Fair Lending Redlining and HMDA Data file, read CRA assessment-area versus lending footprint against an exception rate twice as high for one group after credit controls and write the one fact that would move a redlining pattern exists for model-risk partner for credit scoring.

Recommendation