Assess whether a model update needs a fair-lending revalidation after a DOJ

Situation

A small-business desk using a new vendor score cannot treat a DOJ or CFPB monitor request for pricing files as color commentary on adverse-action notice principal-reason sample. Model-risk partner for credit scoring must close a model update needs from that extract under Fair Lending / Pricing and Credit Limits.

Decision

Model-risk partner for credit scoring in a small-business desk using a new vendor score must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using adverse-action notice principal-reason sample after a DOJ or CFPB monitor request for pricing files.

Hypotheses to test

• Adverse-action notice principal-reason sample reads as Remove access or reverse the item once a DOJ or CFPB monitor request for pricing files is lined up to the same Fair Lending population.
• Adverse-action notice principal-reason sample is closer to Temporary compensating control after a DOJ or CFPB monitor request for pricing files; Remove access or reverse the item would over-claim this Pricing and Credit Limits extract.
• Approve a documented exception is still live in adverse-action notice principal-reason sample for model-risk partner for credit scoring in a small-business desk using a new vendor score.
• Adverse-action notice principal-reason sample is missing the fact model-risk partner for credit scoring needs after a DOJ or CFPB monitor request for pricing files; stop this Fair Lending close.

Analysis required

• Check HMDA coding and underwriting policy against a model update needs.
• Compare adverse-action notice principal-reason sample to similarly situated files, second-review notes, and reason codes after a DOJ or CFPB monitor request for pricing files.
• Flag any disparate-impact table model-risk partner for credit scoring cannot explain from adverse-action notice principal-reason sample.
• For this Fair Lending Pricing and Credit Limits file, read adverse-action notice principal-reason sample against a DOJ or CFPB monitor request for pricing files and write the one fact that would move a model update needs 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 / Pricing and Credit Limits packet (adverse-action notice principal-reason sample after a DOJ or CFPB monitor request for pricing files). If adverse-action notice principal-reason sample cannot force a Fair Lending label under Pricing and Credit Limits, stop. Do not invent pages a small-business desk using a new vendor score does not have.