Assess whether a model update needs a fair-lending revalidation (1d904d)

Situation

The desk packet is credit-card limit assignment disparity table after a HMDA resubmission that still fails quality edits. CRA strategist in a mortgage company after a pricing-regression spike has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending CRA and Special-Purpose Programs file.

Decision

CRA strategist in a mortgage company after a pricing-regression spike 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 HMDA resubmission that still fails quality edits.

Hypotheses to test

• Authorize Remove access or reverse the item now; credit-card limit assignment disparity table already has the discriminator after a HMDA resubmission that still fails quality edits.
• Keep Temporary compensating control in force until credit-card limit assignment disparity table is completed after a HMDA resubmission that still fails quality edits for CRA strategist.
• Treat credit-card limit assignment disparity table as Approve a documented exception because both readings appear after a HMDA resubmission that still fails quality edits.
• Refuse a Fair Lending close: CRA strategist does not have the page a model update needs turns on in credit-card limit assignment disparity table.

Analysis required

• Test a documented exception versus a pattern a mortgage company after a pricing-regression spike must defend.
• 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.
• For this Fair Lending CRA and Special-Purpose Programs file, read credit-card limit assignment disparity table against a HMDA resubmission that still fails quality edits 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 / CRA and Special-Purpose Programs packet (credit-card limit assignment disparity table after a HMDA resubmission that still fails quality edits). The follow-on CRA and Special-Purpose Programs action is what CRA strategist does next: implement the option, assign an owner, and log the missing fact.