Model-risk partner for credit scoring must resolve whether comparative files

Situation

After a vendor score change with no disparate-impact test, HMDA LAR validity and quality edits is what model-risk partner for credit scoring can touch in a small-business desk using a new vendor score. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this Pricing and Credit Limits file.

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 HMDA LAR validity and quality edits after a vendor score change with no disparate-impact test.

Hypotheses to test

• Authorize Remove access or reverse the item now; HMDA LAR validity and quality edits already has the discriminator after a vendor score change with no disparate-impact test.
• Keep Temporary compensating control in force until HMDA LAR validity and quality edits is completed after a vendor score change with no disparate-impact test for model-risk partner for credit scoring.
• Treat HMDA LAR validity and quality edits as Approve a documented exception because both readings appear after a vendor score change with no disparate-impact test.
• Refuse a Fair Lending close: model-risk partner for credit scoring does not have the page comparative files show second-review turns on in HMDA LAR validity and quality edits.

Analysis required

• Test a documented exception versus a pattern a small-business desk using a new vendor score must defend.
• Match the adverse-action language to the facts in HMDA LAR validity and quality edits.
• Check HMDA coding and underwriting policy against comparative files show second-review.
• For this Fair Lending Pricing and Credit Limits file, read HMDA LAR validity and quality edits against a vendor score change with no disparate-impact test and write the one fact that would move comparative files show second-review 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 (HMDA LAR validity and quality edits after a vendor score change with no disparate-impact test). Lead with the Fair Lending option HMDA LAR validity and quality edits can support after a vendor score change with no disparate-impact test, then the two facts that force it, then the Monday action for model-risk partner for credit scoring in a small-business desk using a new vendor score.