Assess whether a model update needs a fair-lending revalidation (341dc6)

Situation

An underwriter chat that used coded language put model-reason-code mapping that does not match notices in front of model-risk partner for credit scoring in a lender expanding into majority-minority census tracts. This Fair Lending / Examination and Notices close is a model update needs from model-reason-code mapping that does not match notices, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

Decision

Model-risk partner for credit scoring in a lender expanding into majority-minority census tracts 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 an underwriter chat that used coded language.

Hypotheses to test

• Authorize Remove access or reverse the item now; model-reason-code mapping that does not match notices already has the discriminator after an underwriter chat that used coded language.
• Keep Temporary compensating control in force until model-reason-code mapping that does not match notices is completed after an underwriter chat that used coded language for model-risk partner for credit scoring.
• Treat model-reason-code mapping that does not match notices as Approve a documented exception because both readings appear after an underwriter chat that used coded language.
• Refuse a Fair Lending close: model-risk partner for credit scoring does not have the page a model update needs turns on in model-reason-code mapping that does not match notices.

Analysis required

• Check HMDA coding and underwriting policy against a model update needs.
• Compare model-reason-code mapping that does not match notices to similarly situated files, second-review notes, and reason codes after an underwriter chat that used coded language.
• Flag any disparate-impact table model-risk partner for credit scoring cannot explain from 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 an underwriter chat that used coded language and write the one fact that would move a model update needs for model-risk partner for credit scoring.

Recommendation