Control detail

Credit model fairness testing

ctl-040 · DETECTIVE · QUARTERLY

ctl-040

Underwriting model outcomes are tested for disparate impact before release.

Key control
Type
DETECTIVE
Automation
SEMI_AUTOMATED
Frequency
QUARTERLY
Owner
Model Risk Management

Control Design Assessment (CDA)

Procedures evaluating whether the control is designed adequately.

  1. 1.Obtain and read the fairness-testing procedure; confirm it requires disparate-impact testing across protected classes before any model release.
  2. 2.Confirm the testing methodology and pass/fail thresholds are approved by model risk management prior to use.

Control Operating Effectiveness (COE)

Procedures evaluating whether the control operated over the testing period.

  1. 1.Confirm the current production model version has a completed fairness test on file dated before its release.
  2. 2.Select model versions released in the period and confirm each has fairness-testing evidence predating release.
  3. 3.Confirm any fairness findings were remediated or risk-accepted with documented approval before release.

Linked risks

  • Credit model fairness exposuremitigation 3

Framework mappings & latest test

GRC-11
Latest test:FAIL2026-03-15