Assess whether a model update needs a fair-lending revalidation (85980e)

Situation

A small-business desk using a new vendor score cannot treat a branch that stopped taking applications in one ZIP as color commentary on credit-card limit assignment disparity table. Adverse-action notice operations lead must close a model update needs from that extract under Fair Lending / CRA and Special-Purpose Programs.

Decision

Adverse-action notice operations lead 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 credit-card limit assignment disparity table after a branch that stopped taking applications in one ZIP.

Hypotheses to test

• Credit-card limit assignment disparity table reads as Remove access or reverse the item once a branch that stopped taking applications in one ZIP is lined up to the same Fair Lending population.
• Credit-card limit assignment disparity table is closer to Temporary compensating control after a branch that stopped taking applications in one ZIP; Remove access or reverse the item would over-claim this CRA and Special-Purpose Programs extract.
• Approve a documented exception is still live in credit-card limit assignment disparity table for adverse-action notice operations lead in a small-business desk using a new vendor score.
• Credit-card limit assignment disparity table is missing the fact adverse-action notice operations lead needs after a branch that stopped taking applications in one ZIP; stop this Fair Lending close.

Analysis required

• Match the adverse-action language to the facts in credit-card limit assignment disparity table.
• Check HMDA coding and underwriting policy against a model update needs.
• Compare credit-card limit assignment disparity table to similarly situated files, second-review notes, and reason codes after a branch that stopped taking applications in one ZIP.
• For this Fair Lending CRA and Special-Purpose Programs file, read credit-card limit assignment disparity table against a branch that stopped taking applications in one ZIP and write the one fact that would move a model update needs for adverse-action notice operations lead.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / CRA and Special-Purpose Programs packet (credit-card limit assignment disparity table after a branch that stopped taking applications in one ZIP). The follow-on CRA and Special-Purpose Programs action is what adverse-action notice operations lead does next: implement the option, assign an owner, and log the missing fact.