Adverse-action notice operations lead must resolve whether a model update

Situation

Pricing and Credit Limits work in a credit union rolling out a special-purpose credit program now turns on a model update needs because a vendor score change with no disparate-impact test put model-reason-code mapping that does not match notices in play. Adverse-action notice operations lead should say what model-reason-code mapping that does not match notices proves.

Decision

Adverse-action notice operations lead in a credit union rolling out a special-purpose credit program must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using model-reason-code mapping that does not match notices after a vendor score change with no disparate-impact test.

Hypotheses to test

• A vendor score change with no disparate-impact test is noise around an already-controlled Pricing and Credit Limits process in a credit union rolling out a special-purpose credit program, given model-reason-code mapping that does not match notices.
• A vendor score change with no disparate-impact test is the event in model-reason-code mapping that does not match notices that forces Remove access or reverse the item for adverse-action notice operations lead under Fair Lending.
• Model-reason-code mapping that does not match notices shows a one-file miss after a vendor score change with no disparate-impact test, not a Pricing and Credit Limits program failure.
• Model-reason-code mapping that does not match notices cannot decide a model update needs yet after a vendor score change with no disparate-impact test; hold is the only Fair Lending close a credit union rolling out a special-purpose credit program can defend.

Analysis required

• Compare model-reason-code mapping that does not match notices to similarly situated files, second-review notes, and reason codes after a vendor score change with no disparate-impact test.
• Flag any disparate-impact table adverse-action notice operations lead cannot explain from model-reason-code mapping that does not match notices.
• Test a documented exception versus a pattern a credit union rolling out a special-purpose credit program must defend.
• For this Fair Lending Pricing and Credit Limits file, read model-reason-code mapping that does not match notices against a vendor score change with no disparate-impact test and write the one fact that would move a model update needs for adverse-action notice operations lead.