Assess whether a model update needs a fair-lending revalidation (b12c64)

Situation

Adverse-action notice operations lead owns a model update needs inside a credit-card issuer changing line-assignment logic with model-reason-code mapping that does not match notices as the only packet. A community complaint about appraisal gaps is what changed the clock for this Fair Lending Examination and Notices file.

Decision

Adverse-action notice operations lead in a credit-card issuer changing line-assignment logic must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using model-reason-code mapping that does not match notices after a community complaint about appraisal gaps.

Hypotheses to test

• Model-reason-code mapping that does not match notices reads as Remove access or reverse the item once a community complaint about appraisal gaps is lined up to the same Fair Lending population.
• Model-reason-code mapping that does not match notices is closer to Temporary compensating control after a community complaint about appraisal gaps; Remove access or reverse the item would over-claim this Examination and Notices extract.
• Approve a documented exception is still live in model-reason-code mapping that does not match notices for adverse-action notice operations lead in a credit-card issuer changing line-assignment logic.
• Model-reason-code mapping that does not match notices is missing the fact adverse-action notice operations lead needs after a community complaint about appraisal gaps; stop this Fair Lending close.

Analysis required

• Flag any disparate-impact table adverse-action notice operations lead cannot explain from model-reason-code mapping that does not match notices.
• Test a documented exception versus a pattern a credit-card issuer changing line-assignment logic must defend.
• Match the adverse-action language to the facts in model-reason-code mapping that does not match notices.
• For this Fair Lending Examination and Notices file, read model-reason-code mapping that does not match notices against a community complaint about appraisal gaps and write the one fact that would move a model update needs for adverse-action notice operations lead.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Examination and Notices packet (model-reason-code mapping that does not match notices after a community complaint about appraisal gaps). Lead with the Fair Lending option model-reason-code mapping that does not match notices can support after a community complaint about appraisal gaps, then the two facts that force it, then the Monday action for adverse-action notice operations lead in a credit-card issuer changing line-assignment logic.