Assess whether a redlining pattern exists after controls (eb378e)

Situation

A notice that cites 'other' as the principal reason 40% of the time put credit-card limit assignment disparity table in front of model-risk partner for credit scoring in a credit union rolling out a special-purpose credit program. This Fair Lending / Redlining and HMDA Data close is a redlining pattern exists from credit-card limit assignment disparity table, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

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 notice that cites 'other' as the principal reason 40% of the time.

Hypotheses to test

• Model-risk partner for credit scoring can defend Remove access or reverse the item from credit-card limit assignment disparity table after a notice that cites 'other' as the principal reason 40% of the time in a Fair Lending challenge.
• Model-risk partner for credit scoring cannot defend Remove access or reverse the item from credit-card limit assignment disparity table; Temporary compensating control is what the extract actually supports after a notice that cites 'other' as the principal reason 40% of the time.
• A notice that cites 'other' as the principal reason 40% of the time never reached the population in credit-card limit assignment disparity table — reopen intake, do not close a redlining pattern exists.
• Two facts in credit-card limit assignment disparity table after a notice that cites 'other' as the principal reason 40% of the time conflict for model-risk partner for credit scoring; hold this Redlining and HMDA Data file.

Analysis required

• Match the adverse-action language to the facts in credit-card limit assignment disparity table.
• Check HMDA coding and underwriting policy against a redlining pattern exists.
• Compare credit-card limit assignment disparity table to similarly situated files, second-review notes, and reason codes after a notice that cites 'other' as the principal reason 40% of the time.
• For this Fair Lending Redlining and HMDA Data file, read credit-card limit assignment disparity table against a notice that cites 'other' as the principal reason 40% of the time and write the one fact that would move a redlining pattern exists for model-risk partner for credit scoring.