Assess whether comparative files show second-review bias (4ce7c2)

Situation

The desk packet is SPCP written plan versus actual originations after a vendor score change with no disparate-impact test. Model-risk partner for credit scoring in a credit-card issuer changing line-assignment logic has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending CRA and Special-Purpose Programs file.

Decision

Model-risk partner for credit scoring in a credit-card issuer changing line-assignment logic must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using SPCP written plan versus actual originations after a vendor score change with no disparate-impact test.

Hypotheses to test

• Authorize Remove access or reverse the item now; SPCP written plan versus actual originations already has the discriminator after a vendor score change with no disparate-impact test.
• Keep Temporary compensating control in force until SPCP written plan versus actual originations is completed after a vendor score change with no disparate-impact test for model-risk partner for credit scoring.
• Treat SPCP written plan versus actual originations 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 SPCP written plan versus actual originations.

Analysis required

• Compare SPCP written plan versus actual originations to similarly situated files, second-review notes, and reason codes after a vendor score change with no disparate-impact test.
• Flag any disparate-impact table model-risk partner for credit scoring cannot explain from SPCP written plan versus actual originations.
• Test a documented exception versus a pattern a credit-card issuer changing line-assignment logic must defend.
• For this Fair Lending CRA and Special-Purpose Programs file, read SPCP written plan versus actual originations 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 / CRA and Special-Purpose Programs packet (SPCP written plan versus actual originations after a vendor score change with no disparate-impact test). Lead with the Fair Lending option SPCP written plan versus actual originations 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 credit-card issuer changing line-assignment logic.