Assess whether a model update needs a fair-lending revalidation (54297f)

Situation

Credit-card limit assignment disparity table arrived with a DOJ or CFPB monitor request for pricing files for fair-lending officer. That is a Fair Lending CRA and Special-Purpose Programs decision on a model update needs in a bank with thin HMDA LAR quality.

Decision

Fair-lending officer 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 credit-card limit assignment disparity table after a DOJ or CFPB monitor request for pricing files.

Hypotheses to test

• Authorize Remove access or reverse the item now; credit-card limit assignment disparity table already has the discriminator after a DOJ or CFPB monitor request for pricing files.
• Keep Temporary compensating control in force until credit-card limit assignment disparity table is completed after a DOJ or CFPB monitor request for pricing files for fair-lending officer.
• Treat credit-card limit assignment disparity table as Approve a documented exception because both readings appear after a DOJ or CFPB monitor request for pricing files.
• Refuse a Fair Lending close: fair-lending officer does not have the page a model update needs turns on in credit-card limit assignment disparity table.

Analysis required

• Match the adverse-action language to the facts in credit-card limit assignment disparity table.
• Check HMDA coding and underwriting policy against a model update needs.
• Compare credit-card limit assignment disparity table to similarly situated files, second-review notes, and reason codes after a DOJ or CFPB monitor request for pricing files.
• For this Fair Lending CRA and Special-Purpose Programs file, read credit-card limit assignment disparity table against a DOJ or CFPB monitor request for pricing files and write the one fact that would move a model update needs for fair-lending officer.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / CRA and Special-Purpose Programs packet (credit-card limit assignment disparity table after a DOJ or CFPB monitor request for pricing files). The follow-on CRA and Special-Purpose Programs action is what fair-lending officer does next: implement the option, assign an owner, and log the missing fact.