Assess whether to pause a product pending a lookback (f91b84)

SITUATION A live Fair Lending CRA and Special-Purpose Programs file in a credit-card issuer changing line-assignment logic now turns on SPCP written plan versus actual originations after a vendor score change with no disparate-impact test. Model-risk partner for credit scoring should state what that extract proves for whether to pause a product pending a lookback.

DECISION Model-risk partner for credit scoring in a credit-card issuer changing line-assignment logic must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using SPCP written plan versus actual originations after a vendor score change with no disparate-impact test.

HYPOTHESES TO TEST 1. A vendor score change with no disparate-impact test is noise around an already-controlled CRA and Special-Purpose Programs process in a credit-card issuer changing line-assignment logic, given SPCP written plan versus actual originations. 2. A vendor score change with no disparate-impact test is the event in SPCP written plan versus actual originations that forces Remove access or reverse the item for model-risk partner for credit scoring under Fair Lending. 3. SPCP written plan versus actual originations shows a one-file miss after a vendor score change with no disparate-impact test, not a CRA and Special-Purpose Programs program failure. 4. SPCP written plan versus actual originations cannot decide to pause a product yet after a vendor score change with no disparate-impact test; hold is the only Fair Lending close a credit-card issuer changing line-assignment logic can defend.

ANALYSIS REQUIRED 1. Flag any disparate-impact table model-risk partner for credit scoring cannot explain from SPCP written plan versus actual originations. 2. Test a documented exception versus a pattern a credit-card issuer changing line-assignment logic must defend. 3. Match the adverse-action language to the facts in SPCP written plan versus actual originations. 4. For this Fair Lending CRA and Special-Purpose Programs file, read SPCP written plan versus actual originations 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 Model-risk partner for credit scoring should take Temporary compensating control on to pause a product unless SPCP written plan versus actual originations after a vendor score change with no disparate-impact test already proves Remove access or reverse the item for this CRA and Special-Purpose Programs packet in a credit-card issuer changing line-assignment logic. Keep Approve a documented exception live only while SPCP written plan versus actual originations is missing the decision to pause a product turns on. The working test on SPCP written plan versus actual originations is whether Flag any disparate-impact table model-risk partner for credit scoring cannot explain from .