Assess whether a model update needs a fair-lending revalidation (e537e2)

Situation

A model update needs sits with CRA strategist because a marketing mailer that skipped majority-minority tracts hit an institution preparing for a redlining exam. Evidence is CRA assessment-area versus lending footprint; write the Fair Lending Redlining and HMDA Data option that extract can carry.

Decision

CRA strategist 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 CRA assessment-area versus lending footprint after a marketing mailer that skipped majority-minority tracts.

Hypotheses to test

• CRA strategist can defend Remove access or reverse the item from CRA assessment-area versus lending footprint after a marketing mailer that skipped majority-minority tracts in a Fair Lending challenge.
• CRA strategist cannot defend Remove access or reverse the item from CRA assessment-area versus lending footprint; Temporary compensating control is what the extract actually supports after a marketing mailer that skipped majority-minority tracts.
• A marketing mailer that skipped majority-minority tracts never reached the population in CRA assessment-area versus lending footprint — reopen intake, do not close a model update needs.
• Two facts in CRA assessment-area versus lending footprint after a marketing mailer that skipped majority-minority tracts conflict for CRA strategist; hold this Redlining and HMDA Data file.

Analysis required

• Flag any disparate-impact table CRA strategist cannot explain from CRA assessment-area versus lending footprint.
• Test a documented exception versus a pattern an institution preparing for a redlining exam must defend.
• Match the adverse-action language to the facts in CRA assessment-area versus lending footprint.
• For this Fair Lending Redlining and HMDA Data file, read CRA assessment-area versus lending footprint against a marketing mailer that skipped majority-minority tracts and write the one fact that would move a model update needs for CRA strategist.

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 (CRA assessment-area versus lending footprint after a marketing mailer that skipped majority-minority tracts). Lead with the Fair Lending option CRA assessment-area versus lending footprint can support after a marketing mailer that skipped majority-minority tracts, then the two facts that force it, then the Monday action for CRA strategist in an institution preparing for a redlining exam.