Assess whether to pause a product pending a lookback (87167b)

SITUATION Adverse-action notice principal-reason sample arrived with a DOJ or CFPB monitor request for pricing files for model-risk partner for credit scoring; this Fair Lending CRA and Special-Purpose Programs close is to pause a product in a credit-card issuer changing line-assignment logic. That is a Fair Lending CRA and Special-Purpose Programs decision on to pause a product in a credit-card issuer changing line-assignment logic.

DECISION Model-risk partner for credit scoring in a credit-card issuer changing line-assignment logic must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using adverse-action notice principal-reason sample after a DOJ or CFPB monitor request for pricing files.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; adverse-action notice principal-reason sample already has the discriminator after a DOJ or CFPB monitor request for pricing files. 2. Keep Temporary compensating control in force until adverse-action notice principal-reason sample is completed after a DOJ or CFPB monitor request for pricing files for model-risk partner for credit scoring. 3. Treat adverse-action notice principal-reason sample as Approve a documented exception because both readings appear after a DOJ or CFPB monitor request for pricing files. 4. Refuse a Fair Lending close: model-risk partner for credit scoring does not have the decision to pause a product turns on in adverse-action notice principal-reason sample.

ANALYSIS REQUIRED 1. Compare adverse-action notice principal-reason sample to similarly situated files, second-review notes, and reason codes after a DOJ or CFPB monitor request for pricing files. 2. Flag any disparate-impact table model-risk partner for credit scoring cannot explain from adverse-action notice principal-reason sample. 3. Test a documented exception versus a pattern a credit-card issuer changing line-assignment logic must defend. 4. For this Fair Lending CRA and Special-Purpose Programs file, read adverse-action notice principal-reason sample against a DOJ or CFPB monitor request for pricing files and write the one fact that would move to pause a product 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 / CRA and Special-Purpose Programs packet (adverse-action notice principal-reason sample after a DOJ or CFPB monitor request for pricing files). The follow-on CRA and Special-Purpose Programs action is what model-risk partner for credit scoring does next: implement the option, assign an owner, and log the missing fact.