Whether a redlining pattern exists after controls from underwriting exception

Situation

A redlining pattern exists sits with model-risk partner for credit scoring because a vendor score change with no disparate-impact test hit a small-business desk using a new vendor score. Evidence is underwriting exception log by branch; write the Fair Lending Pricing and Credit Limits option that extract can carry.

Decision

Model-risk partner for credit scoring in a small-business desk using a new vendor score 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

• The population in underwriting exception log by branch is the one a vendor score change with no disparate-impact test named, so Remove access or reverse the item follows for this Pricing and Credit Limits file.
• The population in underwriting exception log by branch is adjacent only to a vendor score change with no disparate-impact test; Temporary compensating control is the honest Fair Lending call.
• A small-business desk using a new vendor score already contained a vendor score change with no disparate-impact test before underwriting exception log by branch arrived; no new Pricing and Credit Limits path.
• Provenance on underwriting exception log by branch after a vendor score change with no disparate-impact test is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Match the adverse-action language to the facts in underwriting exception log by branch.
• Check HMDA coding and underwriting policy against a redlining pattern exists.
• 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.
• For this Fair Lending Pricing and Credit Limits 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 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 / Pricing and Credit Limits 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 small-business desk using a new vendor score.