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

SITUATION A lender expanding into majority-minority census tracts cannot treat a vendor score change with no disparate-impact test as incidental context on CRA assessment-area versus lending footprint for this Fair Lending Examination and Notices line assignments have a. Model-risk partner for credit scoring must close line assignments have a from that extract under Fair Lending / Examination and Notices.

DECISION Model-risk partner for credit scoring in a lender expanding into majority-minority census tracts 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 vendor score change with no disparate-impact test.

HYPOTHESES TO TEST 1. CRA assessment-area versus lending footprint reads as Remove access or reverse the item once a vendor score change with no disparate-impact test is lined up to the same Fair Lending population. 2. CRA assessment-area versus lending footprint is closer to Temporary compensating control after a vendor score change with no disparate-impact test; Remove access or reverse the item would over-claim this Examination and Notices 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 lender expanding into majority-minority census tracts. 4. CRA assessment-area versus lending footprint is missing the fact model-risk partner for credit scoring needs after a vendor score change with no disparate-impact test; 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 lender expanding into majority-minority census tracts must defend. 3. Match the adverse-action language to the facts in CRA assessment-area versus lending footprint. 4. For this Fair Lending Examination and Notices file, read CRA assessment-area versus lending footprint against a vendor score change with no disparate-impact test 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 / Examination and Notices packet (CRA assessment-area versus lending footprint after a vendor score change with no disparate-impact test). Lead with the Fair Lending option CRA assessment-area versus lending footprint can support after a vendor score change with no disparate-impact test, then the two facts that force it, then the Monday action for model-risk partner for credit scoring in a lender expanding into majority-minority census tracts.