Assess whether a model update needs a fair-lending revalidation (78d868)

Situation

The CRA and Special-Purpose Programs desk packet is geographic application and origination heat map after a vendor score change with no disparate-impact test. Community-development lender in an institution preparing for a redlining exam must name Remove access or reverse the item or Temporary compensating control for this Fair Lending file. Community-development lender in an institution preparing for a redlining exam has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending CRA and Special-Purpose Programs file.

Decision

Community-development lender in an institution preparing for a redlining exam must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using geographic application and origination heat map after a vendor score change with no disparate-impact test.

Hypotheses to test

• The population in geographic application and origination heat map is the one a vendor score change with no disparate-impact test named, so Remove access or reverse the item follows for this CRA and Special-Purpose Programs file.
• The population in geographic application and origination heat map is adjacent only to a vendor score change with no disparate-impact test; Temporary compensating control is the honest Fair Lending call.
• An institution preparing for a redlining exam already contained a vendor score change with no disparate-impact test before geographic application and origination heat map arrived; no new CRA and Special-Purpose Programs path.
• Provenance on geographic application and origination heat map after a vendor score change with no disparate-impact test is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Check HMDA coding and underwriting policy against a model update needs.
• Compare geographic application and origination heat map to similarly situated files, second-review notes, and reason codes after a vendor score change with no disparate-impact test.
• Flag any disparate-impact table community-development lender cannot explain from geographic application and origination heat map.
• For this Fair Lending CRA and Special-Purpose Programs file, read geographic application and origination heat map against a vendor score change with no disparate-impact test and write the one fact that would move a model update needs for community-development lender.