Assess whether to pause a product pending a lookback after a SPCP that

SITUATION A small-business desk using a new vendor score cannot treat a SPCP that originated almost no loans to the intended class as incidental context on CRA assessment-area versus lending footprint. Model-risk partner for credit scoring must close to pause a product from that extract under Fair Lending / Pricing and Credit Limits.

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 CRA assessment-area versus lending footprint after a SPCP that originated almost no loans to the intended class.

HYPOTHESES TO TEST 1. Model-risk partner for credit scoring can defend Remove access or reverse the item from CRA assessment-area versus lending footprint after a SPCP that originated almost no loans to the intended class in a Fair Lending challenge. 2. Model-risk partner for credit scoring cannot defend Remove access or reverse the item from CRA assessment-area versus lending footprint; Temporary compensating control is what the extract actually supports after a SPCP that originated almost no loans to the intended class. 3. A SPCP that originated almost no loans to the intended class never reached the population in CRA assessment-area versus lending footprint — reopen intake, do not close to pause a product. 4. Two facts in CRA assessment-area versus lending footprint after a SPCP that originated almost no loans to the intended class conflict for model-risk partner for credit scoring; hold this Pricing and Credit Limits file.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern a small-business desk using a new vendor score must defend. 2. Match the adverse-action language to the facts in CRA assessment-area versus lending footprint. 3. Check HMDA coding and underwriting policy against to pause a product. 4. For this Fair Lending Pricing and Credit Limits file, read CRA assessment-area versus lending footprint against a SPCP that originated almost no loans to the intended class and write the one fact that would move to pause a product for model-risk partner for credit scoring.

RECOMMENDATION A small-business desk using a new vendor score needs a named owner on to pause a product. Assign model-risk partner for credit scoring to execute Remove access or reverse the item when CRA assessment-area versus lending footprint after a SPCP that originated almost no loans to the intended class is complete, or Temporary compensating control when the Pricing and Credit Limits packet still lacks the discriminator in CRA assessment-area versus lending footprint.

COMMAND RETURNS - Bottom-line Fair Lending option on to pause a product, then the evidence in CRA assessment-area versus lending footprint, then the action for model-risk partner for credit scoring - Hypothesis scorecard against CRA assessment-area versus lending footprint: supported / rejected / untestable - What changes to pause a product if a SPCP that originated almost no loans to the intended class is later withdrawn - Named option among Remove access or reverse the item, Temporary compensating control, Approve a documented exception and the fact that kills the others