Assess whether a model update needs a fair-lending revalidation (b396ed)

Situation

Underwriting exception log by branch arrived with an underwriter chat that used coded language for HMDA data-quality manager. That is a Fair Lending CRA and Special-Purpose Programs decision on a model update needs in a credit union rolling out a special-purpose credit program.

Decision

HMDA data-quality manager in a credit union rolling out a special-purpose credit program must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using underwriting exception log by branch after an underwriter chat that used coded language.

Hypotheses to test

• HMDA data-quality manager can defend Remove access or reverse the item from underwriting exception log by branch after an underwriter chat that used coded language in a Fair Lending challenge.
• HMDA data-quality manager cannot defend Remove access or reverse the item from underwriting exception log by branch; Temporary compensating control is what the extract actually supports after an underwriter chat that used coded language.
• An underwriter chat that used coded language never reached the population in underwriting exception log by branch — reopen intake, do not close a model update needs.
• Two facts in underwriting exception log by branch after an underwriter chat that used coded language conflict for HMDA data-quality manager; hold this CRA and Special-Purpose Programs file.

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 an underwriter chat that used coded language.
• Flag any disparate-impact table HMDA data-quality manager cannot explain from underwriting exception log by branch.
• For this Fair Lending CRA and Special-Purpose Programs file, read underwriting exception log by branch against an underwriter chat that used coded language and write the one fact that would move a model update needs for HMDA data-quality manager.

Recommendation

HMDA data-quality manager should take Temporary compensating control on a model update needs unless underwriting exception log by branch after an underwriter chat that used coded language already proves Remove access or reverse the item for this CRA and Special-Purpose Programs packet in a credit union rolling out a special-purpose credit program. Keep Approve a documented exception live only while underwriting exception log by branch is missing the page a model update needs turns on. The working test on underwriting exception log by branch is whether Check HMDA coding and underwriting policy against a model update needs..