Assess whether dealer overlays introduce prohibited steering (10b3a6)

Situation

Dealer overlays introduce prohibited sits with model-risk partner for credit scoring because a SPCP that originated almost no loans to the intended class hit a credit union rolling out a special-purpose credit program. Evidence is small-business decline comparative file set; write the Fair Lending Redlining and HMDA Data option that extract can carry.

Decision

Model-risk partner for credit scoring 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 small-business decline comparative file set after a SPCP that originated almost no loans to the intended class.

Hypotheses to test

• Model-risk partner for credit scoring can defend Remove access or reverse the item from small-business decline comparative file set after a SPCP that originated almost no loans to the intended class in a Fair Lending challenge.
• Model-risk partner for credit scoring cannot defend Remove access or reverse the item from small-business decline comparative file set; Temporary compensating control is what the extract actually supports after a SPCP that originated almost no loans to the intended class.
• A SPCP that originated almost no loans to the intended class never reached the population in small-business decline comparative file set — reopen intake, do not close dealer overlays introduce prohibited.
• Two facts in small-business decline comparative file set after a SPCP that originated almost no loans to the intended class conflict for model-risk partner for credit scoring; hold this Redlining and HMDA Data file.

Analysis required

• Flag any disparate-impact table model-risk partner for credit scoring cannot explain from small-business decline comparative file set.
• Test a documented exception versus a pattern a credit union rolling out a special-purpose credit program must defend.
• Match the adverse-action language to the facts in small-business decline comparative file set.
• For this Fair Lending Redlining and HMDA Data file, read small-business decline comparative file set against a SPCP that originated almost no loans to the intended class and write the one fact that would move dealer overlays introduce prohibited for model-risk partner for credit scoring.