Assess whether a redlining pattern exists after controls (94ae19)

Situation

Model-risk partner for credit scoring owns a redlining pattern exists inside a credit-card issuer changing line-assignment logic with CRA assessment-area versus lending footprint as the only packet. A vendor score change with no disparate-impact test is what changed the clock 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 CRA assessment-area versus lending footprint after a vendor score change with no disparate-impact test.

Hypotheses to test

• Model-risk partner for credit scoring can defend Remove access or reverse the item from CRA assessment-area versus lending footprint after a vendor score change with no disparate-impact test in a Fair Lending challenge.
• Model-risk partner for credit scoring cannot defend Remove access or reverse the item from CRA assessment-area versus lending footprint; Temporary compensating control is what the extract actually supports after a vendor score change with no disparate-impact test.
• A vendor score change with no disparate-impact test never reached the population in CRA assessment-area versus lending footprint — reopen intake, do not close a redlining pattern exists.
• Two facts in CRA assessment-area versus lending footprint after a vendor score change with no disparate-impact test conflict for model-risk partner for credit scoring; hold this CRA and Special-Purpose Programs file.

Analysis required

• Match the adverse-action language to the facts in CRA assessment-area versus lending footprint.
• Check HMDA coding and underwriting policy against a redlining pattern exists.
• Compare CRA assessment-area versus lending footprint to similarly situated files, second-review notes, and reason codes after a vendor score change with no disparate-impact test.
• For this Fair Lending CRA and Special-Purpose Programs file, read CRA assessment-area versus lending footprint against a vendor score change with no disparate-impact test and write the one fact that would move a redlining pattern exists for model-risk partner for credit scoring.

Recommendation