Assess whether line assignments have a disparate impact the bank will defend

SITUATION Model-risk partner for credit scoring is responsible for line assignments have a in a credit-card issuer changing line-assignment logic, using CRA assessment-area versus lending footprint as the only working extract. A SPCP that originated almost no loans to the intended class is what reset the timeline for this Fair Lending CRA and Special-Purpose Programs file.

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

HYPOTHESES TO TEST 1. CRA assessment-area versus lending footprint reads as Remove access or reverse the item once a SPCP that originated almost no loans to the intended class is lined up to the same Fair Lending population. 2. CRA assessment-area versus lending footprint is closer to Temporary compensating control after a SPCP that originated almost no loans to the intended class; Remove access or reverse the item would over-claim this CRA and Special-Purpose Programs extract. 3. Approve a documented exception is still live in CRA assessment-area versus lending footprint for model-risk partner for credit scoring in a credit-card issuer changing line-assignment logic. 4. CRA assessment-area versus lending footprint is missing the fact model-risk partner for credit scoring needs after a SPCP that originated almost no loans to the intended class; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Flag any disparate-impact table model-risk partner for credit scoring cannot explain from CRA assessment-area versus lending footprint. 2. Test a documented exception versus a pattern a credit-card issuer changing line-assignment logic must defend. 3. Match the adverse-action language to the facts in CRA assessment-area versus lending footprint. 4. For this Fair Lending CRA and Special-Purpose Programs 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 line assignments have a 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 (CRA assessment-area versus lending footprint after a SPCP that originated almost no loans to the intended class). If CRA assessment-area versus lending footprint cannot force a Fair Lending label under CRA and Special-Purpose Programs, stop. If CRA assessment-area versus lending footprint after a SPCP that originated almost no loans to the intended class cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending CRA and Special-Purpose Programs close, model-risk partner for credit scoring must do not infer a control or scheme beyond the transaction and entitlement evidence.