Assess whether a model update needs a fair-lending revalidation (f47d18)

Situation

In a manufactured-housing lender with dealer-originated files, geographic application and origination heat map is the evidence after a marketing mailer that skipped majority-minority tracts. Community-development lender has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending Examination and Notices close using geographic application and origination heat map.

Decision

Community-development lender in a manufactured-housing lender with dealer-originated files must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using geographic application and origination heat map after a marketing mailer that skipped majority-minority tracts.

Hypotheses to test

• Authorize Remove access or reverse the item now; geographic application and origination heat map already has the discriminator after a marketing mailer that skipped majority-minority tracts.
• Keep Temporary compensating control in force until geographic application and origination heat map is completed after a marketing mailer that skipped majority-minority tracts for community-development lender.
• Treat geographic application and origination heat map as Approve a documented exception because both readings appear after a marketing mailer that skipped majority-minority tracts.
• Refuse a Fair Lending close: community-development lender does not have the page a model update needs turns on in geographic application and origination heat map.

Analysis required

• Flag any disparate-impact table community-development lender cannot explain from geographic application and origination heat map.
• Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend.
• Match the adverse-action language to the facts in geographic application and origination heat map.
• For this Fair Lending Examination and Notices file, read geographic application and origination heat map against a marketing mailer that skipped majority-minority tracts 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 / Examination and Notices packet (geographic application and origination heat map after a marketing mailer that skipped majority-minority tracts). Lead with the Fair Lending option geographic application and origination heat map can support after a marketing mailer that skipped majority-minority tracts, then the two facts that force it, then the Monday action for community-development lender in a manufactured-housing lender with dealer-originated files.