Assess whether a model update needs a fair-lending revalidation (59091f)

Situation

A model update needs sits with model-risk partner for credit scoring because a HMDA resubmission that still fails quality edits hit a credit union rolling out a special-purpose credit program. Evidence is underwriting exception log by branch; write the Fair Lending Redlining and HMDA Data option that extract can carry.

Decision

Model-risk partner for credit scoring 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 a HMDA resubmission that still fails quality edits.

Hypotheses to test

• Model-risk partner for credit scoring can defend Remove access or reverse the item from underwriting exception log by branch after a HMDA resubmission that still fails quality edits in a Fair Lending challenge.
• Model-risk partner for credit scoring cannot defend Remove access or reverse the item from underwriting exception log by branch; Temporary compensating control is what the extract actually supports after a HMDA resubmission that still fails quality edits.
• A HMDA resubmission that still fails quality edits 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 a HMDA resubmission that still fails quality edits conflict for model-risk partner for credit scoring; hold this Redlining and HMDA Data file.

Analysis required

• Compare underwriting exception log by branch to similarly situated files, second-review notes, and reason codes after a HMDA resubmission that still fails quality edits.
• Flag any disparate-impact table model-risk partner for credit scoring cannot explain from underwriting exception log by branch.
• Test a documented exception versus a pattern a credit union rolling out a special-purpose credit program must defend.
• For this Fair Lending Redlining and HMDA Data file, read underwriting exception log by branch against a HMDA resubmission that still fails quality edits and write the one fact that would move a model update needs for model-risk partner for credit scoring.

Recommendation