Assess whether the exam response should concede a finding (2c9fe6)

SITUATION Model-risk partner for credit scoring in a credit union rolling out a special-purpose credit program has one working extract — appraisal-gap outcomes in majority-minority tracts — after a SPCP that originated almost no loans to the intended class. Model-risk partner for credit scoring in a credit union rolling out a special-purpose credit program has appraisal-gap outcomes in majority-minority tracts after a SPCP that originated almost no loans to the intended class. If that extract cannot support the exam response should, the only defensible Fair Lending Redlining and HMDA Data output is hold.

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 appraisal-gap outcomes in majority-minority tracts after a SPCP that originated almost no loans to the intended class.

HYPOTHESES TO TEST 1. The population in appraisal-gap outcomes in majority-minority tracts is the one a SPCP that originated almost no loans to the intended class named, so Remove access or reverse the item follows for this Redlining and HMDA Data file. 2. The population in appraisal-gap outcomes in majority-minority tracts is adjacent only to a SPCP that originated almost no loans to the intended class; Temporary compensating control is the honest Fair Lending call. 3. A credit union rolling out a special-purpose credit program already contained a SPCP that originated almost no loans to the intended class before appraisal-gap outcomes in majority-minority tracts arrived; no new Redlining and HMDA Data path. 4. Provenance on appraisal-gap outcomes in majority-minority tracts after a SPCP that originated almost no loans to the intended class is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

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 appraisal-gap outcomes in majority-minority tracts. 3. Check HMDA coding and underwriting policy against the exam response should. 4. For this Fair Lending Redlining and HMDA Data file, read appraisal-gap outcomes in majority-minority tracts against a SPCP that originated almost no loans to the intended class and write the one fact that would move the exam response should 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 (appraisal-gap outcomes in majority-minority tracts after a SPCP that originated almost no loans to the intended class). If appraisal-gap outcomes in majority-minority tracts cannot force a Fair Lending label under Redlining and HMDA Data, stop. If appraisal-gap outcomes in majority-minority tracts after a SPCP that originated almost no loans to the intended class 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.