Assess whether a model update needs a fair-lending revalidation (7ef50a)

Situation

A model update needs sits with community-development lender because a board asking if the bank should settle a matched-pair study hit an institution preparing for a redlining exam. Evidence is CRA assessment-area versus lending footprint; write the Fair Lending CRA and Special-Purpose Programs option that extract can carry.

Decision

Community-development lender 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 CRA assessment-area versus lending footprint after a board asking if the bank should settle a matched-pair study.

Hypotheses to test

• Community-development lender can defend Remove access or reverse the item from CRA assessment-area versus lending footprint after a board asking if the bank should settle a matched-pair study in a Fair Lending challenge.
• Community-development lender cannot defend Remove access or reverse the item from CRA assessment-area versus lending footprint; Temporary compensating control is what the extract actually supports after a board asking if the bank should settle a matched-pair study.
• A board asking if the bank should settle a matched-pair study never reached the population in CRA assessment-area versus lending footprint — reopen intake, do not close a model update needs.
• Two facts in CRA assessment-area versus lending footprint after a board asking if the bank should settle a matched-pair study conflict for community-development lender; hold this CRA and Special-Purpose Programs file.

Analysis required

• Match the adverse-action language to the facts in CRA assessment-area versus lending footprint.
• Check HMDA coding and underwriting policy against a model update needs.
• Compare CRA assessment-area versus lending footprint to similarly situated files, second-review notes, and reason codes after a board asking if the bank should settle a matched-pair study.
• For this Fair Lending CRA and Special-Purpose Programs file, read CRA assessment-area versus lending footprint against a board asking if the bank should settle a matched-pair study and write the one fact that would move a model update needs for community-development lender.

Recommendation