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

SITUATION After a board asking if the bank should settle a matched-pair study, small-business decline comparative file set is what model-risk partner for credit scoring can touch in a credit union rolling out a special-purpose credit program. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this Redlining and HMDA Data file.

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 board asking if the bank should settle a matched-pair study.

HYPOTHESES TO TEST 1. The population in small-business decline comparative file set is the one a board asking if the bank should settle a matched-pair study named, so Remove access or reverse the item follows for this Redlining and HMDA Data file. 2. The population in small-business decline comparative file set is adjacent only to a board asking if the bank should settle a matched-pair study; Temporary compensating control is the honest Fair Lending call. 3. A credit union rolling out a special-purpose credit program already contained a board asking if the bank should settle a matched-pair study before small-business decline comparative file set arrived; no new Redlining and HMDA Data path. 4. Provenance on small-business decline comparative file set after a board asking if the bank should settle a matched-pair study is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

ANALYSIS REQUIRED 1. Flag any disparate-impact table model-risk partner for credit scoring cannot explain from small-business decline comparative file set. 2. Test a documented exception versus a pattern a credit union rolling out a special-purpose credit program must defend. 3. Match the adverse-action language to the facts in small-business decline comparative file set. 4. For this Fair Lending Redlining and HMDA Data file, read small-business decline comparative file set against a board asking if the bank should settle a matched-pair study 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 (small-business decline comparative file set after a board asking if the bank should settle a matched-pair study). The follow-on Redlining and HMDA Data action is what model-risk partner for credit scoring does next: implement the option, assign an owner, and log the missing fact.