Assess whether a model update needs a fair-lending revalidation (a16933)
August 31, 2026 · SmartSolo
Situation
A manufactured-housing lender with dealer-originated files cannot treat a DOJ or CFPB monitor request for pricing files as color commentary on model-reason-code mapping that does not match notices. Exam-response coordinator must close a model update needs from that extract under Fair Lending / CRA and Special-Purpose Programs.
Decision
Exam-response coordinator 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 model-reason-code mapping that does not match notices after a DOJ or CFPB monitor request for pricing files.
Hypotheses to test
- A DOJ or CFPB monitor request for pricing files is noise around an already-controlled CRA and Special-Purpose Programs process in a manufactured-housing lender with dealer-originated files, given model-reason-code mapping that does not match notices.
- A DOJ or CFPB monitor request for pricing files is the event in model-reason-code mapping that does not match notices that forces Remove access or reverse the item for exam-response coordinator under Fair Lending.
- Model-reason-code mapping that does not match notices shows a one-file miss after a DOJ or CFPB monitor request for pricing files, not a CRA and Special-Purpose Programs program failure.
- Model-reason-code mapping that does not match notices cannot decide a model update needs yet after a DOJ or CFPB monitor request for pricing files; hold is the only Fair Lending close a manufactured-housing lender with dealer-originated files can defend.
Analysis required
- Check HMDA coding and underwriting policy against a model update needs.
- Compare model-reason-code mapping that does not match notices to similarly situated files, second-review notes, and reason codes after a DOJ or CFPB monitor request for pricing files.
- Flag any disparate-impact table exam-response coordinator cannot explain from model-reason-code mapping that does not match notices.
- For this Fair Lending CRA and Special-Purpose Programs file, read model-reason-code mapping that does not match notices against a DOJ or CFPB monitor request for pricing files and write the one fact that would move a model update needs for exam-response coordinator.
Recommendation
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