Assess whether a model update needs a fair-lending revalidation (026a8f)

Situation

CRA strategist owns a model update needs inside a bank with thin HMDA LAR quality with HMDA LAR validity and quality edits as the only packet. An underwriter chat that used coded language is what changed the clock for this Fair Lending Examination and Notices file.

Decision

CRA strategist 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 HMDA LAR validity and quality edits after an underwriter chat that used coded language.

Hypotheses to test

• An underwriter chat that used coded language is noise around an already-controlled Examination and Notices process in a bank with thin HMDA LAR quality, given HMDA LAR validity and quality edits.
• An underwriter chat that used coded language is the event in HMDA LAR validity and quality edits that forces Remove access or reverse the item for CRA strategist under Fair Lending.
• HMDA LAR validity and quality edits shows a one-file miss after an underwriter chat that used coded language, not a Examination and Notices program failure.
• HMDA LAR validity and quality edits cannot decide a model update needs yet after an underwriter chat that used coded language; hold is the only Fair Lending close a bank with thin HMDA LAR quality can defend.

Analysis required

• Compare HMDA LAR validity and quality edits to similarly situated files, second-review notes, and reason codes after an underwriter chat that used coded language.
• Flag any disparate-impact table CRA strategist cannot explain from HMDA LAR validity and quality edits.
• Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend.
• For this Fair Lending Examination and Notices file, read HMDA LAR validity and quality edits against an underwriter chat that used coded language 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 / Examination and Notices packet (HMDA LAR validity and quality edits after an underwriter chat that used coded language). Lead with the Fair Lending option HMDA LAR validity and quality edits can support after an underwriter chat that used coded language, then the two facts that force it, then the Monday action for CRA strategist in a bank with thin HMDA LAR quality.