Whether a model update needs a fair-lending revalidation from mortgage

Situation

A model update needs sits with community-development lender because a HMDA resubmission that still fails quality edits hit a bank with thin HMDA LAR quality. Evidence is mortgage pricing residual by prohibited-basis group; write the Fair Lending Pricing and Credit Limits option that extract can carry.

Decision

Community-development lender in a bank with thin HMDA LAR quality must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using mortgage pricing residual by prohibited-basis group after a HMDA resubmission that still fails quality edits.

Hypotheses to test

• Mortgage pricing residual by prohibited-basis group reads as Remove access or reverse the item once a HMDA resubmission that still fails quality edits is lined up to the same Fair Lending population.
• Mortgage pricing residual by prohibited-basis group is closer to Temporary compensating control after a HMDA resubmission that still fails quality edits; Remove access or reverse the item would over-claim this Pricing and Credit Limits extract.
• Approve a documented exception is still live in mortgage pricing residual by prohibited-basis group for community-development lender in a bank with thin HMDA LAR quality.
• Mortgage pricing residual by prohibited-basis group is missing the fact community-development lender needs after a HMDA resubmission that still fails quality edits; stop this Fair Lending close.

Analysis required

• Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend.
• Match the adverse-action language to the facts in mortgage pricing residual by prohibited-basis group.
• Check HMDA coding and underwriting policy against a model update needs.
• For this Fair Lending Pricing and Credit Limits file, read mortgage pricing residual by prohibited-basis group against a HMDA resubmission that still fails quality edits and write the one fact that would move a model update needs for community-development lender.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Pricing and Credit Limits packet (mortgage pricing residual by prohibited-basis group after a HMDA resubmission that still fails quality edits). If mortgage pricing residual by prohibited-basis group cannot force a Fair Lending label under Pricing and Credit Limits, stop. Do not invent pages a bank with thin HMDA LAR quality does not have.