Assess whether a special-purpose program is well designed or a pretext

Situation

After a vendor score change with no disparate-impact test, adverse-action notice principal-reason sample is what model-risk partner for credit scoring can touch in a credit-card issuer changing line-assignment logic. Fair Lending will live with A special-purpose program is well designed versus A pretext on this CRA and Special-Purpose Programs file.

Decision

Model-risk partner for credit scoring in a credit-card issuer changing line-assignment logic must choose A special-purpose program is well designed / A pretext using adverse-action notice principal-reason sample after a vendor score change with no disparate-impact test.

Hypotheses to test

• A vendor score change with no disparate-impact test is noise around an already-controlled CRA and Special-Purpose Programs process in a credit-card issuer changing line-assignment logic, given adverse-action notice principal-reason sample.
• A vendor score change with no disparate-impact test is the event in adverse-action notice principal-reason sample that forces A special-purpose program is well designed for model-risk partner for credit scoring under Fair Lending.
• Adverse-action notice principal-reason sample shows a one-file miss after a vendor score change with no disparate-impact test, not a CRA and Special-Purpose Programs program failure.
• Adverse-action notice principal-reason sample cannot decide a special-purpose program is yet after a vendor score change with no disparate-impact test; hold is the only Fair Lending close a credit-card issuer changing line-assignment logic can defend.

Analysis required

• Match the adverse-action language to the facts in adverse-action notice principal-reason sample.
• Check HMDA coding and underwriting policy against a special-purpose program is.
• Compare adverse-action notice principal-reason sample to similarly situated files, second-review notes, and reason codes after a vendor score change with no disparate-impact test.
• For this Fair Lending CRA and Special-Purpose Programs file, read adverse-action notice principal-reason sample against a vendor score change with no disparate-impact test and write the one fact that would move a special-purpose program is for model-risk partner for credit scoring.

Recommendation