Assess whether a model update needs a fair-lending revalidation (4f83af)

Situation

The desk packet is small-business decline comparative file set after a vendor score change with no disparate-impact test. Community-development lender in a mortgage company after a pricing-regression spike has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending Redlining and HMDA Data file.

Decision

Community-development lender in a mortgage company after a pricing-regression spike must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using small-business decline comparative file set after a vendor score change with no disparate-impact test.

Hypotheses to test

• Small-business decline comparative file set reads as Remove access or reverse the item once a vendor score change with no disparate-impact test is lined up to the same Fair Lending population.
• Small-business decline comparative file set is closer to Temporary compensating control after a vendor score change with no disparate-impact test; Remove access or reverse the item would over-claim this Redlining and HMDA Data extract.
• Approve a documented exception is still live in small-business decline comparative file set for community-development lender in a mortgage company after a pricing-regression spike.
• Small-business decline comparative file set is missing the fact community-development lender needs after a vendor score change with no disparate-impact test; stop this Fair Lending close.

Analysis required

• Compare small-business decline comparative file set to similarly situated files, second-review notes, and reason codes after a vendor score change with no disparate-impact test.
• Flag any disparate-impact table community-development lender cannot explain from small-business decline comparative file set.
• Test a documented exception versus a pattern a mortgage company after a pricing-regression spike must defend.
• For this Fair Lending Redlining and HMDA Data file, read small-business decline comparative file set against a vendor score change with no disparate-impact test and write the one fact that would move a model update needs for community-development lender.

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 (small-business decline comparative file set after a vendor score change with no disparate-impact test). Lead with the Fair Lending option small-business decline comparative file set can support after a vendor score change with no disparate-impact test, then the two facts that force it, then the Monday action for community-development lender in a mortgage company after a pricing-regression spike.