Assess whether a special-purpose program is well designed or a pretext

Situation

A HMDA resubmission that still fails quality edits put appraisal-gap outcomes in majority-minority tracts in front of model-risk partner for credit scoring in a small-business desk using a new vendor score. This Fair Lending / Pricing and Credit Limits close is a special-purpose program is from appraisal-gap outcomes in majority-minority tracts, and the live options are A special-purpose program is well designed, A pretext.

Decision

Model-risk partner for credit scoring in a small-business desk using a new vendor score must choose A special-purpose program is well designed / A pretext using appraisal-gap outcomes in majority-minority tracts after a HMDA resubmission that still fails quality edits.

Hypotheses to test

• A HMDA resubmission that still fails quality edits is noise around an already-controlled Pricing and Credit Limits process in a small-business desk using a new vendor score, given appraisal-gap outcomes in majority-minority tracts.
• A HMDA resubmission that still fails quality edits is the event in appraisal-gap outcomes in majority-minority tracts that forces A special-purpose program is well designed for model-risk partner for credit scoring under Fair Lending.
• Appraisal-gap outcomes in majority-minority tracts shows a one-file miss after a HMDA resubmission that still fails quality edits, not a Pricing and Credit Limits program failure.
• Appraisal-gap outcomes in majority-minority tracts cannot decide a special-purpose program is yet after a HMDA resubmission that still fails quality edits; hold is the only Fair Lending close a small-business desk using a new vendor score can defend.

Analysis required

• Compare appraisal-gap outcomes in majority-minority tracts to similarly situated files, second-review notes, and reason codes after a HMDA resubmission that still fails quality edits.
• Flag any disparate-impact table model-risk partner for credit scoring cannot explain from appraisal-gap outcomes in majority-minority tracts.
• 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 appraisal-gap outcomes in majority-minority tracts against a HMDA resubmission that still fails quality edits and write the one fact that would move a special-purpose program is for model-risk partner for credit scoring.