Assess whether a model update needs a fair-lending revalidation from SPCP

Situation

After a marketing mailer that skipped majority-minority tracts, SPCP written plan versus actual originations is what exam-response coordinator can touch in an institution preparing for a redlining exam. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this Pricing and Credit Limits file.

Decision

Exam-response coordinator in an institution preparing for a redlining exam must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using SPCP written plan versus actual originations after a marketing mailer that skipped majority-minority tracts.

Hypotheses to test

• Authorize Remove access or reverse the item now; SPCP written plan versus actual originations already has the discriminator after a marketing mailer that skipped majority-minority tracts.
• Keep Temporary compensating control in force until SPCP written plan versus actual originations is completed after a marketing mailer that skipped majority-minority tracts for exam-response coordinator.
• Treat SPCP written plan versus actual originations as Approve a documented exception because both readings appear after a marketing mailer that skipped majority-minority tracts.
• Refuse a Fair Lending close: exam-response coordinator does not have the page a model update needs turns on in SPCP written plan versus actual originations.

Analysis required

• Compare SPCP written plan versus actual originations to similarly situated files, second-review notes, and reason codes after a marketing mailer that skipped majority-minority tracts.
• Flag any disparate-impact table exam-response coordinator cannot explain from SPCP written plan versus actual originations.
• Test a documented exception versus a pattern an institution preparing for a redlining exam must defend.
• For this Fair Lending Pricing and Credit Limits file, read SPCP written plan versus actual originations against a marketing mailer that skipped majority-minority tracts 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 / Pricing and Credit Limits packet (SPCP written plan versus actual originations after a marketing mailer that skipped majority-minority tracts). If SPCP written plan versus actual originations cannot force a Fair Lending label under Pricing and Credit Limits, stop. Do not invent pages an institution preparing for a redlining exam does not have.