Assess whether a model update needs a fair-lending revalidation (6be1c8)

Situation

Examination and Notices work in a bank with thin HMDA LAR quality now turns on a model update needs because a community complaint about appraisal gaps put credit-card limit assignment disparity table in play. Examination and Notices work in a bank with thin HMDA LAR quality now turns on a model update needs because a community complaint about appraisal gaps put credit-card limit assignment disparity table in play; CRA strategist should say what credit-card limit assignment disparity table proves for Fair Lending.

Decision

CRA strategist 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 credit-card limit assignment disparity table after a community complaint about appraisal gaps.

Hypotheses to test

• A community complaint about appraisal gaps is noise around an already-controlled Examination and Notices process in a bank with thin HMDA LAR quality, given credit-card limit assignment disparity table.
• A community complaint about appraisal gaps is the event in credit-card limit assignment disparity table that forces Remove access or reverse the item for CRA strategist under Fair Lending.
• Credit-card limit assignment disparity table shows a one-file miss after a community complaint about appraisal gaps, not a Examination and Notices program failure.
• Credit-card limit assignment disparity table cannot decide a model update needs yet after a community complaint about appraisal gaps; hold is the only Fair Lending close a bank with thin HMDA LAR quality can defend.

Analysis required

• Compare credit-card limit assignment disparity table to similarly situated files, second-review notes, and reason codes after a community complaint about appraisal gaps.
• Flag any disparate-impact table CRA strategist cannot explain from credit-card limit assignment disparity table.
• Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend.
• For this Fair Lending Examination and Notices file, read credit-card limit assignment disparity table against a community complaint about appraisal gaps and write the one fact that would move a model update needs for CRA strategist.

Recommendation