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

Situation

After a CRA PE that called the assessment area too narrow, model-reason-code mapping that does not match notices is what model-risk partner for credit scoring can touch in a lender expanding into majority-minority census tracts. Fair Lending will live with A special-purpose program is well designed versus A pretext on this Examination and Notices file.

Decision

Model-risk partner for credit scoring in a lender expanding into majority-minority census tracts must choose A special-purpose program is well designed / A pretext using model-reason-code mapping that does not match notices after a CRA PE that called the assessment area too narrow.

Hypotheses to test

• The population in model-reason-code mapping that does not match notices is the one a CRA PE that called the assessment area too narrow named, so A special-purpose program is well designed follows for this Examination and Notices file.
• The population in model-reason-code mapping that does not match notices is adjacent only to a CRA PE that called the assessment area too narrow; A pretext is the honest Fair Lending call.
• A lender expanding into majority-minority census tracts already contained a CRA PE that called the assessment area too narrow before model-reason-code mapping that does not match notices arrived; no new Examination and Notices path.
• Provenance on model-reason-code mapping that does not match notices after a CRA PE that called the assessment area too narrow is broken; do not pick A special-purpose program is well designed or A pretext yet.

Analysis required

• Flag any disparate-impact table model-risk partner for credit scoring cannot explain from model-reason-code mapping that does not match notices.
• Test a documented exception versus a pattern a lender expanding into majority-minority census tracts must defend.
• Match the adverse-action language to the facts in model-reason-code mapping that does not match notices.
• For this Fair Lending Examination and Notices file, read model-reason-code mapping that does not match notices against a CRA PE that called the assessment area too narrow and write the one fact that would move a special-purpose program is for model-risk partner for credit scoring.

Recommendation