Assess whether a model update needs a fair-lending revalidation (4be0a6)

Situation

CRA strategist owns a model update needs inside a bank with thin HMDA LAR quality with SPCP written plan versus actual originations as the only packet. A vendor score change with no disparate-impact test is what changed the clock for this Fair Lending Examination and Notices file.

Decision

CRA strategist in a bank with thin HMDA LAR quality must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using SPCP written plan versus actual originations after a vendor score change with no disparate-impact test.

Hypotheses to test

• SPCP written plan versus actual originations reads as Remove access or reverse the item once a vendor score change with no disparate-impact test is lined up to the same Fair Lending population.
• SPCP written plan versus actual originations is closer to Temporary compensating control after a vendor score change with no disparate-impact test; Remove access or reverse the item would over-claim this Examination and Notices extract.
• Approve a documented exception is still live in SPCP written plan versus actual originations for CRA strategist in a bank with thin HMDA LAR quality.
• SPCP written plan versus actual originations is missing the fact CRA strategist needs after a vendor score change with no disparate-impact test; stop this Fair Lending close.

Analysis required

• Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend.
• Match the adverse-action language to the facts in SPCP written plan versus actual originations.
• Check HMDA coding and underwriting policy against a model update needs.
• For this Fair Lending Examination and Notices file, read SPCP written plan versus actual originations against a vendor score change with no disparate-impact test and write the one fact that would move a model update needs for CRA strategist.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Examination and Notices packet (SPCP written plan versus actual originations after a vendor score change with no disparate-impact test). Lead with the Fair Lending option SPCP written plan versus actual originations can support after a vendor score change with no disparate-impact test, then the two facts that force it, then the Monday action for CRA strategist in a bank with thin HMDA LAR quality.