Whether to pause a product pending a lookback from appraisal-gap outcomes in

SITUATION Model-risk partner for credit scoring in a small-business desk using a new vendor score has one working extract — appraisal-gap outcomes in majority-minority tracts — after a SPCP that originated almost no loans to the intended class. If appraisal-gap outcomes in majority-minority tracts 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 appraisal-gap outcomes in majority-minority tracts after a SPCP that originated almost no loans to the intended class.

HYPOTHESES TO TEST 1. Model-risk partner for credit scoring can defend Remove access or reverse the item from appraisal-gap outcomes in majority-minority tracts after a SPCP that originated almost no loans to the intended class in a Fair Lending challenge. 2. Model-risk partner for credit scoring cannot defend Remove access or reverse the item from appraisal-gap outcomes in majority-minority tracts; Temporary compensating control is what the extract actually supports after a SPCP that originated almost no loans to the intended class. 3. A SPCP that originated almost no loans to the intended class never reached the population in appraisal-gap outcomes in majority-minority tracts — reopen intake, do not close to pause a product. 4. Two facts in appraisal-gap outcomes in majority-minority tracts after a SPCP that originated almost no loans to the intended class conflict for model-risk partner for credit scoring; hold this Pricing and Credit Limits file.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against to pause a product. 2. Compare appraisal-gap outcomes in majority-minority tracts to similarly situated files, second-review notes, and reason codes after a SPCP that originated almost no loans to the intended class. 3. Flag any disparate-impact table model-risk partner for credit scoring cannot explain from appraisal-gap outcomes in majority-minority tracts. 4. For this Fair Lending Pricing and Credit Limits file, read appraisal-gap outcomes in majority-minority tracts against a SPCP that originated almost no loans to the intended class 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 (appraisal-gap outcomes in majority-minority tracts after a SPCP that originated almost no loans to the intended class). Lead with the Fair Lending option appraisal-gap outcomes in majority-minority tracts can support after a SPCP that originated almost no loans to the intended class, then the two facts that force it, then the Monday action for model-risk partner for credit scoring in a small-business desk using a new vendor score.