Assess whether a model update needs a fair-lending revalidation (b5de3d)

Situation

After an exception rate twice as high for one group after credit controls, mortgage pricing residual by prohibited-basis group is what second-review underwriter can touch in a credit-card issuer changing line-assignment logic. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this Pricing and Credit Limits file.

Decision

Second-review underwriter 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 mortgage pricing residual by prohibited-basis group after an exception rate twice as high for one group after credit controls.

Hypotheses to test

• The population in mortgage pricing residual by prohibited-basis group is the one an exception rate twice as high for one group after credit controls named, so Remove access or reverse the item follows for this Pricing and Credit Limits file.
• The population in mortgage pricing residual by prohibited-basis group is adjacent only to an exception rate twice as high for one group after credit controls; Temporary compensating control is the honest Fair Lending call.
• A credit-card issuer changing line-assignment logic already contained an exception rate twice as high for one group after credit controls before mortgage pricing residual by prohibited-basis group arrived; no new Pricing and Credit Limits path.
• Provenance on mortgage pricing residual by prohibited-basis group after an exception rate twice as high for one group after credit controls 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 mortgage pricing residual by prohibited-basis group.
• Check HMDA coding and underwriting policy against a model update needs.
• Compare mortgage pricing residual by prohibited-basis group to similarly situated files, second-review notes, and reason codes after an exception rate twice as high for one group after credit controls.
• For this Fair Lending Pricing and Credit Limits file, read mortgage pricing residual by prohibited-basis group against an exception rate twice as high for one group after credit controls and write the one fact that would move a model update needs for second-review underwriter.