Assess whether notices match the actual decisioning reasons (2adc03)

SITUATION After a board asking if the bank should settle a matched-pair study, credit-card limit assignment disparity table is what model-risk partner for credit scoring can touch in a credit union rolling out a special-purpose credit program. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this Redlining and HMDA Data file.

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 credit-card limit assignment disparity table after a board asking if the bank should settle a matched-pair study.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; credit-card limit assignment disparity table already has the discriminator after a board asking if the bank should settle a matched-pair study. 2. Keep Temporary compensating control in force until credit-card limit assignment disparity table is completed after a board asking if the bank should settle a matched-pair study for model-risk partner for credit scoring. 3. Treat credit-card limit assignment disparity table as Approve a documented exception because both readings appear after a board asking if the bank should settle a matched-pair study. 4. Refuse a Fair Lending close: model-risk partner for credit scoring does not have the decision notices match the actual turns on in credit-card limit assignment disparity table.

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 credit-card limit assignment disparity table. 3. Check HMDA coding and underwriting policy against notices match the actual. 4. For this Fair Lending Redlining and HMDA Data file, read credit-card limit assignment disparity table against a board asking if the bank should settle a matched-pair study and write the one fact that would move notices match the actual 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 (credit-card limit assignment disparity table after a board asking if the bank should settle a matched-pair study). The follow-on Redlining and HMDA Data action is what model-risk partner for credit scoring does next: implement the option, assign an owner, and log the missing fact.

COMMAND RETURNS - Bottom-line Fair Lending option on notices match the actual, then the evidence in credit-card limit assignment disparity table, then the action for model-risk partner for credit scoring - Hypothesis scorecard against credit-card limit assignment disparity table: supported / rejected / untestable - Missing page in credit-card limit assignment disparity table after a board asking if the bank should settle a matched-pair study, if any - Regulatory or exam hook Redlining and HMDA Data would cite