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

SITUATION Redlining and HMDA Data work in a credit union rolling out a special-purpose credit program now turns on line assignments have a because a notice that cites 'other' as the principal reason 40% of the time put model-reason-code mapping that does not match notices in play. Redlining and HMDA Data work in a credit union rolling out a special-purpose credit program now turns on line assignments have a because a notice that cites 'other' as the principal reason 40% of the time put model-reason-code mapping that does not match notices in play; model-risk partner for credit scoring should say what model-reason-code mapping that does not match notices proves for Fair Lending.

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 model-reason-code mapping that does not match notices after a notice that cites 'other' as the principal reason 40% of the time.

HYPOTHESES TO TEST 1. A notice that cites 'other' as the principal reason 40% of the time is noise around an already-controlled Redlining and HMDA Data process in a credit union rolling out a special-purpose credit program, given model-reason-code mapping that does not match notices. 2. A notice that cites 'other' as the principal reason 40% of the time is the event in model-reason-code mapping that does not match notices that forces Remove access or reverse the item for model-risk partner for credit scoring under Fair Lending. 3. Model-reason-code mapping that does not match notices shows a one-file miss after a notice that cites 'other' as the principal reason 40% of the time, not a Redlining and HMDA Data program failure. 4. Model-reason-code mapping that does not match notices cannot decide line assignments have a yet after a notice that cites 'other' as the principal reason 40% of the time; hold is the only Fair Lending close a credit union rolling out a special-purpose credit program can defend.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in model-reason-code mapping that does not match notices. 2. Check HMDA coding and underwriting policy against line assignments have a. 3. Compare model-reason-code mapping that does not match notices to similarly situated files, second-review notes, and reason codes after a notice that cites 'other' as the principal reason 40% of the time. 4. For this Fair Lending Redlining and HMDA Data file, read model-reason-code mapping that does not match notices against a notice that cites 'other' as the principal reason 40% of the time 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 / Redlining and HMDA Data packet (model-reason-code mapping that does not match notices after a notice that cites 'other' as the principal reason 40% of the time). Lead with the Fair Lending option model-reason-code mapping that does not match notices can support after a notice that cites 'other' as the principal reason 40% of the time, then the two facts that force it, then the Monday action for model-risk partner for credit scoring in a credit union rolling out a special-purpose credit program.