Whether the exam response should concede a finding from manufactured-housing

SITUATION The working file is manufactured-housing dealer overlay notes after a vendor score change with no disparate-impact test. Model-risk partner for credit scoring in a small-business desk using a new vendor score has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending 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 manufactured-housing dealer overlay notes after a vendor score change with no disparate-impact test.

HYPOTHESES TO TEST 1. A vendor score change with no disparate-impact test is noise around an already-controlled Pricing and Credit Limits process in a small-business desk using a new vendor score, given manufactured-housing dealer overlay notes. 2. A vendor score change with no disparate-impact test is the event in manufactured-housing dealer overlay notes that forces Remove access or reverse the item for model-risk partner for credit scoring under Fair Lending. 3. Manufactured-housing dealer overlay notes shows a one-file miss after a vendor score change with no disparate-impact test, not a Pricing and Credit Limits program failure. 4. Manufactured-housing dealer overlay notes cannot decide the exam response should yet after a vendor score change with no disparate-impact test; hold is the only Fair Lending close a small-business desk using a new vendor score can defend.

ANALYSIS REQUIRED 1. Flag any disparate-impact table model-risk partner for credit scoring cannot explain from manufactured-housing dealer overlay notes. 2. Test a documented exception versus a pattern a small-business desk using a new vendor score must defend. 3. Match the adverse-action language to the facts in manufactured-housing dealer overlay notes. 4. For this Fair Lending Pricing and Credit Limits file, read manufactured-housing dealer overlay notes against a vendor score change with no disparate-impact test 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 / Pricing and Credit Limits packet (manufactured-housing dealer overlay notes after a vendor score change with no disparate-impact test). If manufactured-housing dealer overlay notes cannot force a Fair Lending label under Pricing and Credit Limits, stop. Do not invent missing evidence a small-business desk using a new vendor score does not have.