Assess whether the exam response should concede a finding (66b90f)

SITUATION Model-risk partner for credit scoring is responsible for the exam response should in a credit-card issuer changing line-assignment logic, using SPCP written plan versus actual originations as the only working extract. A marketing mailer that skipped majority-minority tracts is what reset the timeline 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 marketing mailer that skipped majority-minority tracts.

HYPOTHESES TO TEST 1. SPCP written plan versus actual originations reads as Remove access or reverse the item once a marketing mailer that skipped majority-minority tracts is lined up to the same Fair Lending population. 2. SPCP written plan versus actual originations is closer to Temporary compensating control after a marketing mailer that skipped majority-minority tracts; Remove access or reverse the item would over-claim this CRA and Special-Purpose Programs extract. 3. Approve a documented exception is still live in SPCP written plan versus actual originations for model-risk partner for credit scoring in a credit-card issuer changing line-assignment logic. 4. SPCP written plan versus actual originations is missing the fact model-risk partner for credit scoring needs after a marketing mailer that skipped majority-minority tracts; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Flag any disparate-impact table model-risk partner for credit scoring cannot explain from SPCP written plan versus actual originations. 2. Test a documented exception versus a pattern a credit-card issuer changing line-assignment logic must defend. 3. Match the adverse-action language to the facts in SPCP written plan versus actual originations. 4. For this Fair Lending CRA and Special-Purpose Programs file, read SPCP written plan versus actual originations against a marketing mailer that skipped majority-minority tracts 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 / CRA and Special-Purpose Programs packet (SPCP written plan versus actual originations after a marketing mailer that skipped majority-minority tracts). Lead with the Fair Lending option SPCP written plan versus actual originations can support after a marketing mailer that skipped majority-minority tracts, 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.