Assess whether pricing disparities are justified by legitimate factors

SITUATION A board asking if the bank should settle a matched-pair study put underwriting exception log by branch in front of model-risk partner for credit scoring in a credit union rolling out a special-purpose credit program. This Fair Lending / Redlining and HMDA Data close is pricing disparities are justified from underwriting exception log by branch, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

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 underwriting exception log by branch after a board asking if the bank should settle a matched-pair study.

HYPOTHESES TO TEST 1. Model-risk partner for credit scoring can defend Remove access or reverse the item from underwriting exception log by branch after a board asking if the bank should settle a matched-pair study in a Fair Lending challenge. 2. Model-risk partner for credit scoring cannot defend Remove access or reverse the item from underwriting exception log by branch; Temporary compensating control is what the extract actually supports after a board asking if the bank should settle a matched-pair study. 3. A board asking if the bank should settle a matched-pair study never reached the population in underwriting exception log by branch — reopen intake, do not close pricing disparities are justified. 4. Two facts in underwriting exception log by branch after a board asking if the bank should settle a matched-pair study conflict for model-risk partner for credit scoring; hold this Redlining and HMDA Data file.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern a credit union rolling out a special-purpose credit program must defend. 2. Match the adverse-action language to the facts in underwriting exception log by branch. 3. Check HMDA coding and underwriting policy against pricing disparities are justified. 4. For this Fair Lending Redlining and HMDA Data file, read underwriting exception log by branch against a board asking if the bank should settle a matched-pair study and write the one fact that would move pricing disparities are justified 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 (underwriting exception log by branch after a board asking if the bank should settle a matched-pair study). If underwriting exception log by branch cannot force a Fair Lending label under Redlining and HMDA Data, stop. If underwriting exception log by branch after a board asking if the bank should settle a matched-pair study cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending Redlining and HMDA Data close, model-risk partner for credit scoring must do not infer a control or scheme beyond the transaction and entitlement evidence.