Assess whether a model update needs a fair-lending revalidation (0197c4)

Situation

Exam-response coordinator owns a model update needs inside a bank with thin HMDA LAR quality with mortgage pricing residual by prohibited-basis group as the only packet. A branch that stopped taking applications in one ZIP is what changed the clock for this Fair Lending Redlining and HMDA Data file.

Decision

Exam-response coordinator 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 branch that stopped taking applications in one ZIP.

Hypotheses to test

• A branch that stopped taking applications in one ZIP is noise around an already-controlled Redlining and HMDA Data process in a bank with thin HMDA LAR quality, given mortgage pricing residual by prohibited-basis group.
• A branch that stopped taking applications in one ZIP is the event in mortgage pricing residual by prohibited-basis group that forces Remove access or reverse the item for exam-response coordinator under Fair Lending.
• Mortgage pricing residual by prohibited-basis group shows a one-file miss after a branch that stopped taking applications in one ZIP, not a Redlining and HMDA Data program failure.
• Mortgage pricing residual by prohibited-basis group cannot decide a model update needs yet after a branch that stopped taking applications in one ZIP; hold is the only Fair Lending close a bank with thin HMDA LAR quality can defend.

Analysis required

• 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.
• Compare mortgage pricing residual by prohibited-basis group to similarly situated files, second-review notes, and reason codes after a branch that stopped taking applications in one ZIP.
• For this Fair Lending Redlining and HMDA Data file, read mortgage pricing residual by prohibited-basis group against a branch that stopped taking applications in one ZIP and write the one fact that would move a model update needs for exam-response coordinator.

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 (mortgage pricing residual by prohibited-basis group after a branch that stopped taking applications in one ZIP). The follow-on Redlining and HMDA Data action is what exam-response coordinator does next: implement the option, assign an owner, and log the missing fact.