Assess whether a model update needs a fair-lending revalidation (9aee9b)

Situation

A community complaint about appraisal gaps put mortgage pricing residual by prohibited-basis group in front of model-risk partner for credit scoring in a credit union rolling out a special-purpose credit program. This Fair Lending / Redlining and HMDA Data close is a model update needs from mortgage pricing residual by prohibited-basis group, 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 credit union rolling out a special-purpose credit program 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 community complaint about appraisal gaps.

Hypotheses to test

• Authorize Remove access or reverse the item now; mortgage pricing residual by prohibited-basis group already has the discriminator after a community complaint about appraisal gaps.
• Keep Temporary compensating control in force until mortgage pricing residual by prohibited-basis group is completed after a community complaint about appraisal gaps for model-risk partner for credit scoring.
• Treat mortgage pricing residual by prohibited-basis group as Approve a documented exception because both readings appear after a community complaint about appraisal gaps.
• Refuse a Fair Lending close: model-risk partner for credit scoring does not have the page a model update needs turns on in mortgage pricing residual by prohibited-basis group.

Analysis required

• Test a documented exception versus a pattern a credit union rolling out a special-purpose credit program must defend.
• 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.
• For this Fair Lending Redlining and HMDA Data file, read mortgage pricing residual by prohibited-basis group against a community complaint about appraisal gaps and write the one fact that would move a model update needs for model-risk partner for credit scoring.

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 community complaint about appraisal gaps). Lead with the Fair Lending option mortgage pricing residual by prohibited-basis group can support after a community complaint about appraisal gaps, then the two facts that force it, then the Monday action for model-risk partner for credit scoring in a credit union rolling out a special-purpose credit program.