Assess whether a model update needs a fair-lending revalidation (7ab776)

Situation

A community complaint about appraisal gaps put underwriting exception log by branch in front of community-development lender in a mortgage company after a pricing-regression spike. This Fair Lending / Redlining and HMDA Data close is a model update needs from underwriting exception log by branch, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

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 underwriting exception log by branch after a community complaint about appraisal gaps.

Hypotheses to test

• The population in underwriting exception log by branch is the one a community complaint about appraisal gaps named, so Remove access or reverse the item follows for this Redlining and HMDA Data file.
• The population in underwriting exception log by branch is adjacent only to a community complaint about appraisal gaps; Temporary compensating control is the honest Fair Lending call.
• A mortgage company after a pricing-regression spike already contained a community complaint about appraisal gaps before underwriting exception log by branch arrived; no new Redlining and HMDA Data path.
• Provenance on underwriting exception log by branch after a community complaint about appraisal gaps is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Check HMDA coding and underwriting policy against a model update needs.
• Compare underwriting exception log by branch to similarly situated files, second-review notes, and reason codes after a community complaint about appraisal gaps.
• Flag any disparate-impact table community-development lender cannot explain from underwriting exception log by branch.
• For this Fair Lending Redlining and HMDA Data file, read underwriting exception log by branch against a community complaint about appraisal gaps 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 (underwriting exception log by branch after a community complaint about appraisal gaps). The follow-on Redlining and HMDA Data action is what community-development lender does next: implement the option, assign an owner, and log the missing fact.