Assess whether a model update needs a fair-lending revalidation (b80edb)

Situation

In a lender expanding into majority-minority census tracts, geographic application and origination heat map is the evidence after an underwriter chat that used coded language. Adverse-action notice operations lead has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending Redlining and HMDA Data close using geographic application and origination heat map.

Decision

Adverse-action notice operations lead in a lender expanding into majority-minority census tracts must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using geographic application and origination heat map after an underwriter chat that used coded language.

Hypotheses to test

• The population in geographic application and origination heat map is the one an underwriter chat that used coded language named, so Remove access or reverse the item follows for this Redlining and HMDA Data file.
• The population in geographic application and origination heat map is adjacent only to an underwriter chat that used coded language; Temporary compensating control is the honest Fair Lending call.
• A lender expanding into majority-minority census tracts already contained an underwriter chat that used coded language before geographic application and origination heat map arrived; no new Redlining and HMDA Data path.
• Provenance on geographic application and origination heat map after an underwriter chat that used coded language is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Test a documented exception versus a pattern a lender expanding into majority-minority census tracts must defend.
• Match the adverse-action language to the facts in geographic application and origination heat map.
• Check HMDA coding and underwriting policy against a model update needs.
• For this Fair Lending Redlining and HMDA Data file, read geographic application and origination heat map against an underwriter chat that used coded language 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 / Redlining and HMDA Data packet (geographic application and origination heat map after an underwriter chat that used coded language). The follow-on Redlining and HMDA Data action is what adverse-action notice operations lead does next: implement the option, assign an owner, and log the missing fact.