Assess whether to pause a product pending a lookback after a vendor score

SITUATION Model-risk partner for credit scoring in a small-business desk using a new vendor score has one working extract — adverse-action notice principal-reason sample — after a vendor score change with no disparate-impact test. If adverse-action notice principal-reason sample cannot support to pause a product, the only defensible Fair Lending output is hold.

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 adverse-action notice principal-reason sample after a vendor score change with no disparate-impact test.

HYPOTHESES TO TEST 1. The population in adverse-action notice principal-reason sample is the one a vendor score change with no disparate-impact test named, so Remove access or reverse the item follows for this Pricing and Credit Limits file. 2. The population in adverse-action notice principal-reason sample is adjacent only to a vendor score change with no disparate-impact test; Temporary compensating control is the honest Fair Lending call. 3. A small-business desk using a new vendor score already contained a vendor score change with no disparate-impact test before adverse-action notice principal-reason sample arrived; no new Pricing and Credit Limits path. 4. Provenance on adverse-action notice principal-reason sample after a vendor score change with no disparate-impact test is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against to pause a product. 2. Compare adverse-action notice principal-reason sample to similarly situated files, second-review notes, and reason codes after a vendor score change with no disparate-impact test. 3. Flag any disparate-impact table model-risk partner for credit scoring cannot explain from adverse-action notice principal-reason sample. 4. For this Fair Lending Pricing and Credit Limits file, read adverse-action notice principal-reason sample against a vendor score change with no disparate-impact test and write the one fact that would move to pause a product for model-risk partner for credit scoring.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Pricing and Credit Limits packet (adverse-action notice principal-reason sample after a vendor score change with no disparate-impact test). If adverse-action notice principal-reason sample cannot force a Fair Lending label under Pricing and Credit Limits, stop. Do not invent missing evidence a small-business desk using a new vendor score does not have.