Assess whether to pause a product pending a lookback (ff76fb)

SITUATION Model-risk partner for credit scoring in a credit-card issuer changing line-assignment logic has one working extract — credit-card limit assignment disparity table — after a community complaint about appraisal gaps. Model-risk partner for credit scoring in a credit-card issuer changing line-assignment logic has credit-card limit assignment disparity table after a community complaint about appraisal gaps. If that extract cannot support to pause a product, the only defensible Fair Lending CRA and Special-Purpose Programs output is hold.

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 credit-card limit assignment disparity table after a community complaint about appraisal gaps.

HYPOTHESES TO TEST 1. Model-risk partner for credit scoring can defend Remove access or reverse the item from credit-card limit assignment disparity table after a community complaint about appraisal gaps in a Fair Lending challenge. 2. Model-risk partner for credit scoring cannot defend Remove access or reverse the item from credit-card limit assignment disparity table; Temporary compensating control is what the extract actually supports after a community complaint about appraisal gaps. 3. A community complaint about appraisal gaps never reached the population in credit-card limit assignment disparity table — reopen intake, do not close to pause a product. 4. Two facts in credit-card limit assignment disparity table after a community complaint about appraisal gaps conflict for model-risk partner for credit scoring; hold this CRA and Special-Purpose Programs file.

ANALYSIS REQUIRED 1. Compare credit-card limit assignment disparity table to similarly situated files, second-review notes, and reason codes after a community complaint about appraisal gaps. 2. Flag any disparate-impact table model-risk partner for credit scoring cannot explain from credit-card limit assignment disparity table. 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 credit-card limit assignment disparity table against a community complaint about appraisal gaps 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 (credit-card limit assignment disparity table after a community complaint about appraisal gaps). 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.