Assess whether a special-purpose program is well designed or a pretext

Situation

A special-purpose program is sits with model-risk partner for credit scoring because a community complaint about appraisal gaps hit a credit union rolling out a special-purpose credit program. Evidence is SPCP written plan versus actual originations; write the Fair Lending Redlining and HMDA Data option that extract can carry.

Decision

Model-risk partner for credit scoring in a credit union rolling out a special-purpose credit program must choose A special-purpose program is well designed / A pretext using SPCP written plan versus actual originations after a community complaint about appraisal gaps.

Hypotheses to test

• The population in SPCP written plan versus actual originations is the one a community complaint about appraisal gaps named, so A special-purpose program is well designed follows for this Redlining and HMDA Data file.
• The population in SPCP written plan versus actual originations is adjacent only to a community complaint about appraisal gaps; A pretext is the honest Fair Lending call.
• A credit union rolling out a special-purpose credit program already contained a community complaint about appraisal gaps before SPCP written plan versus actual originations arrived; no new Redlining and HMDA Data path.
• Provenance on SPCP written plan versus actual originations after a community complaint about appraisal gaps is broken; do not pick A special-purpose program is well designed or A pretext yet.

Analysis required

• Flag any disparate-impact table model-risk partner for credit scoring cannot explain from SPCP written plan versus actual originations.
• 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 SPCP written plan versus actual originations.
• For this Fair Lending Redlining and HMDA Data file, read SPCP written plan versus actual originations against a community complaint about appraisal gaps and write the one fact that would move a special-purpose program is for model-risk partner for credit scoring.

Recommendation

Choose A special-purpose program is well designed / A pretext on this Fair Lending / Redlining and HMDA Data packet (SPCP written plan versus actual originations after a community complaint about appraisal gaps). Lead with the Fair Lending option SPCP written plan versus actual originations can support after a community complaint about appraisal gaps, 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.