Assess whether a model update needs a fair-lending revalidation (bfab0f)

Situation

Exam-response coordinator in a bank with thin HMDA LAR quality has one working extract — manufactured-housing dealer overlay notes — after a branch that stopped taking applications in one ZIP. If manufactured-housing dealer overlay notes cannot support a model update needs, the honest Fair Lending output is hold.

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 manufactured-housing dealer overlay notes after a branch that stopped taking applications in one ZIP.

Hypotheses to test

• The population in manufactured-housing dealer overlay notes is the one a branch that stopped taking applications in one ZIP named, so Remove access or reverse the item follows for this Redlining and HMDA Data file.
• The population in manufactured-housing dealer overlay notes is adjacent only to a branch that stopped taking applications in one ZIP; Temporary compensating control is the honest Fair Lending call.
• A bank with thin HMDA LAR quality already contained a branch that stopped taking applications in one ZIP before manufactured-housing dealer overlay notes arrived; no new Redlining and HMDA Data path.
• Provenance on manufactured-housing dealer overlay notes after a branch that stopped taking applications in one ZIP is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Match the adverse-action language to the facts in manufactured-housing dealer overlay notes.
• Check HMDA coding and underwriting policy against a model update needs.
• Compare manufactured-housing dealer overlay notes 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 manufactured-housing dealer overlay notes 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 (manufactured-housing dealer overlay notes 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.