Assess whether notices match the actual decisioning reasons (0066b5)

SITUATION CRA and Special-Purpose Programs work in a credit-card issuer changing line-assignment logic now turns on notices match the actual because a DOJ or CFPB monitor request for pricing files put underwriting exception log by branch in play. CRA and Special-Purpose Programs work in a credit-card issuer changing line-assignment logic now turns on notices match the actual because a DOJ or CFPB monitor request for pricing files put underwriting exception log by branch in play; model-risk partner for credit scoring should say what underwriting exception log by branch proves for Fair Lending.

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 underwriting exception log by branch after a DOJ or CFPB monitor request for pricing files.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; underwriting exception log by branch already has the discriminator after a DOJ or CFPB monitor request for pricing files. 2. Keep Temporary compensating control in force until underwriting exception log by branch is completed after a DOJ or CFPB monitor request for pricing files for model-risk partner for credit scoring. 3. Treat underwriting exception log by branch as Approve a documented exception because both readings appear after a DOJ or CFPB monitor request for pricing files. 4. Refuse a Fair Lending close: model-risk partner for credit scoring does not have the decision notices match the actual turns on in underwriting exception log by branch.

ANALYSIS REQUIRED 1. Compare underwriting exception log by branch to similarly situated files, second-review notes, and reason codes after a DOJ or CFPB monitor request for pricing files. 2. Flag any disparate-impact table model-risk partner for credit scoring cannot explain from underwriting exception log by branch. 3. Test a documented exception versus a pattern a credit-card issuer changing line-assignment logic must defend. 4. For this Fair Lending CRA and Special-Purpose Programs file, read underwriting exception log by branch against a DOJ or CFPB monitor request for pricing files 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 / CRA and Special-Purpose Programs packet (underwriting exception log by branch after a DOJ or CFPB monitor request for pricing files). The follow-on CRA and Special-Purpose Programs action is what model-risk partner for credit scoring does next: implement the option, assign an owner, and log the missing fact.