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

Situation

Model-risk partner for credit scoring owns a special-purpose program is inside a credit union rolling out a special-purpose credit program with credit-card limit assignment disparity table as the only packet. A community complaint about appraisal gaps is what changed the clock for this Fair Lending Redlining and HMDA Data file.

Decision

Model-risk partner for credit scoring in a credit union rolling out a special-purpose credit program must choose A special-purpose program is well designed / A pretext using credit-card limit assignment disparity table after a community complaint about appraisal gaps.

Hypotheses to test

• Credit-card limit assignment disparity table reads as A special-purpose program is well designed once a community complaint about appraisal gaps is lined up to the same Fair Lending population.
• Credit-card limit assignment disparity table is closer to A pretext after a community complaint about appraisal gaps; A special-purpose program is well designed would over-claim this Redlining and HMDA Data extract.
• A dual reading is still live in credit-card limit assignment disparity table for model-risk partner for credit scoring in a credit union rolling out a special-purpose credit program.
• Credit-card limit assignment disparity table is missing the fact model-risk partner for credit scoring needs after a community complaint about appraisal gaps; stop this Fair Lending close.

Analysis required

• Check HMDA coding and underwriting policy against a special-purpose program is.
• Compare credit-card limit assignment disparity table to similarly situated files, second-review notes, and reason codes after a community complaint about appraisal gaps.
• Flag any disparate-impact table model-risk partner for credit scoring cannot explain from credit-card limit assignment disparity table.
• For this Fair Lending Redlining and HMDA Data file, read credit-card limit assignment disparity table against a community complaint about appraisal gaps and write the one fact that would move a special-purpose program is for model-risk partner for credit scoring.

Recommendation

Choose A special-purpose program is well designed / A pretext on this Fair Lending / Redlining and HMDA Data packet (credit-card limit assignment disparity table after a community complaint about appraisal gaps). The follow-on Redlining and HMDA Data action is what model-risk partner for credit scoring does next: implement the option, assign an owner, and log the missing fact.