Assess whether a redlining pattern exists after controls (5f721c)

Situation

Redlining and HMDA Data work in a credit union rolling out a special-purpose credit program now turns on a redlining pattern exists because an underwriter chat that used coded language put SPCP written plan versus actual originations in play. Model-risk partner for credit scoring should say what SPCP written plan versus actual originations proves.

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 SPCP written plan versus actual originations after an underwriter chat that used coded language.

Hypotheses to test

• Authorize Remove access or reverse the item now; SPCP written plan versus actual originations already has the discriminator after an underwriter chat that used coded language.
• Keep Temporary compensating control in force until SPCP written plan versus actual originations is completed after an underwriter chat that used coded language for model-risk partner for credit scoring.
• Treat SPCP written plan versus actual originations as Approve a documented exception because both readings appear after an underwriter chat that used coded language.
• Refuse a Fair Lending close: model-risk partner for credit scoring does not have the page a redlining pattern exists turns on in SPCP written plan versus actual originations.

Analysis required

• Match the adverse-action language to the facts in SPCP written plan versus actual originations.
• Check HMDA coding and underwriting policy against a redlining pattern exists.
• Compare SPCP written plan versus actual originations to similarly situated files, second-review notes, and reason codes after an underwriter chat that used coded language.
• For this Fair Lending Redlining and HMDA Data file, read SPCP written plan versus actual originations against an underwriter chat that used coded language and write the one fact that would move a redlining pattern exists 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 / Redlining and HMDA Data packet (SPCP written plan versus actual originations after an underwriter chat that used coded language). Lead with the Fair Lending option SPCP written plan versus actual originations can support after an underwriter chat that used coded language, then the two facts that force it, then the Monday action for model-risk partner for credit scoring in a credit union rolling out a special-purpose credit program.