Assess whether to pause a product pending a lookback from CRA assessment-area

SITUATION A branch that stopped taking applications in one ZIP put CRA assessment-area versus lending footprint 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 to pause a product from CRA assessment-area versus lending footprint, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

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 CRA assessment-area versus lending footprint after a branch that stopped taking applications in one ZIP.

HYPOTHESES TO TEST 1. Model-risk partner for credit scoring can defend Remove access or reverse the item from CRA assessment-area versus lending footprint after a branch that stopped taking applications in one ZIP in a Fair Lending challenge. 2. Model-risk partner for credit scoring cannot defend Remove access or reverse the item from CRA assessment-area versus lending footprint; Temporary compensating control is what the extract actually supports after a branch that stopped taking applications in one ZIP. 3. A branch that stopped taking applications in one ZIP never reached the population in CRA assessment-area versus lending footprint — reopen intake, do not close to pause a product. 4. Two facts in CRA assessment-area versus lending footprint after a branch that stopped taking applications in one ZIP conflict for model-risk partner for credit scoring; hold this Pricing and Credit Limits file.

ANALYSIS REQUIRED 1. Compare CRA assessment-area versus lending footprint to similarly situated files, second-review notes, and reason codes after a branch that stopped taking applications in one ZIP. 2. Flag any disparate-impact table model-risk partner for credit scoring cannot explain from CRA assessment-area versus lending footprint. 3. Test a documented exception versus a pattern a small-business desk using a new vendor score must defend. 4. For this Fair Lending Pricing and Credit Limits file, read CRA assessment-area versus lending footprint against a branch that stopped taking applications in one ZIP 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 (CRA assessment-area versus lending footprint after a branch that stopped taking applications in one ZIP). The follow-on Pricing and Credit Limits action is what model-risk partner for credit scoring does next: implement the option, assign an owner, and log the missing fact.