Assess whether a model update needs a fair-lending revalidation (da6b52)

Situation

A branch that stopped taking applications in one ZIP put geographic application and origination heat map in front of CRA strategist in an institution preparing for a redlining exam. This Fair Lending / Redlining and HMDA Data close is a model update needs from geographic application and origination heat map, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

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 geographic application and origination heat map after a branch that stopped taking applications in one ZIP.

Hypotheses to test

• Authorize Remove access or reverse the item now; geographic application and origination heat map already has the discriminator after a branch that stopped taking applications in one ZIP.
• Keep Temporary compensating control in force until geographic application and origination heat map is completed after a branch that stopped taking applications in one ZIP for CRA strategist.
• Treat geographic application and origination heat map as Approve a documented exception because both readings appear after a branch that stopped taking applications in one ZIP.
• Refuse a Fair Lending close: CRA strategist does not have the page a model update needs turns on in geographic application and origination heat map.

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 branch that stopped taking applications in one ZIP.
• Flag any disparate-impact table CRA strategist cannot explain from geographic application and origination heat map.
• For this Fair Lending Redlining and HMDA Data file, read geographic application and origination heat map against a branch that stopped taking applications in one ZIP 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 (geographic application and origination heat map after a branch that stopped taking applications in one ZIP). Lead with the Fair Lending option geographic application and origination heat map can support after a branch that stopped taking applications in one ZIP, then the two facts that force it, then the Monday action for CRA strategist in an institution preparing for a redlining exam.