Model-risk partner for credit scoring must resolve whether to pause a product

Situation

The desk packet is HMDA LAR validity and quality edits after a HMDA resubmission that still fails quality edits. Model-risk partner for credit scoring in a small-business desk using a new vendor score has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending Pricing and Credit Limits file.

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 HMDA LAR validity and quality edits after a HMDA resubmission that still fails quality edits.

Hypotheses to test

• Authorize Remove access or reverse the item now; HMDA LAR validity and quality edits already has the discriminator after a HMDA resubmission that still fails quality edits.
• Keep Temporary compensating control in force until HMDA LAR validity and quality edits is completed after a HMDA resubmission that still fails quality edits for model-risk partner for credit scoring.
• Treat HMDA LAR validity and quality edits as Approve a documented exception because both readings appear after a HMDA resubmission that still fails quality edits.
• Refuse a Fair Lending close: model-risk partner for credit scoring does not have the page to pause a product turns on in HMDA LAR validity and quality edits.

Analysis required

• Match the adverse-action language to the facts in HMDA LAR validity and quality edits.
• Check HMDA coding and underwriting policy against to pause a product.
• Compare HMDA LAR validity and quality edits to similarly situated files, second-review notes, and reason codes after a HMDA resubmission that still fails quality edits.
• For this Fair Lending Pricing and Credit Limits file, read HMDA LAR validity and quality edits against a HMDA resubmission that still fails quality edits 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 / Pricing and Credit Limits packet (HMDA LAR validity and quality edits after a HMDA resubmission that still fails quality edits). The follow-on Pricing and Credit Limits action is what model-risk partner for credit scoring does next: implement the option, assign an owner, and log the missing fact.