Model-risk partner for credit scoring must resolve whether a redlining

Situation

Underwriting exception log by branch arrived with a marketing mailer that skipped majority-minority tracts for model-risk partner for credit scoring. That is a Fair Lending Pricing and Credit Limits decision on a redlining pattern exists in a small-business desk using a new vendor score.

Decision

Model-risk partner for credit scoring in a small-business desk using a new vendor score must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using underwriting exception log by branch after a marketing mailer that skipped majority-minority tracts.

Hypotheses to test

• Model-risk partner for credit scoring can defend Remove access or reverse the item from underwriting exception log by branch after a marketing mailer that skipped majority-minority tracts in a Fair Lending challenge.
• Model-risk partner for credit scoring cannot defend Remove access or reverse the item from underwriting exception log by branch; Temporary compensating control is what the extract actually supports after a marketing mailer that skipped majority-minority tracts.
• A marketing mailer that skipped majority-minority tracts never reached the population in underwriting exception log by branch — reopen intake, do not close a redlining pattern exists.
• Two facts in underwriting exception log by branch after a marketing mailer that skipped majority-minority tracts conflict for model-risk partner for credit scoring; hold this Pricing and Credit Limits file.

Analysis required

• Compare underwriting exception log by branch to similarly situated files, second-review notes, and reason codes after a marketing mailer that skipped majority-minority tracts.
• Flag any disparate-impact table model-risk partner for credit scoring cannot explain from underwriting exception log by branch.
• Test a documented exception versus a pattern a small-business desk using a new vendor score must defend.
• For this Fair Lending Pricing and Credit Limits file, read underwriting exception log by branch against a marketing mailer that skipped majority-minority tracts and write the one fact that would move a redlining pattern exists for model-risk partner for credit scoring.

Recommendation