Assess whether a model update needs a fair-lending revalidation after a board

Situation

In a credit-card issuer changing line-assignment logic, geographic application and origination heat map is the evidence after a board asking if the bank should settle a matched-pair study. HMDA data-quality manager has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending Redlining and HMDA Data close using geographic application and origination heat map.

Decision

HMDA data-quality manager in a credit-card issuer changing line-assignment logic 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 board asking if the bank should settle a matched-pair study.

Hypotheses to test

• HMDA data-quality manager can defend Remove access or reverse the item from geographic application and origination heat map after a board asking if the bank should settle a matched-pair study in a Fair Lending challenge.
• HMDA data-quality manager cannot defend Remove access or reverse the item from geographic application and origination heat map; 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 geographic application and origination heat map — reopen intake, do not close a model update needs.
• Two facts in geographic application and origination heat map after a board asking if the bank should settle a matched-pair study conflict for HMDA data-quality manager; hold this Redlining and HMDA Data file.

Analysis required

• Match the adverse-action language to the facts in geographic application and origination heat map.
• Check HMDA coding and underwriting policy against a model update needs.
• Compare geographic application and origination heat map 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 Redlining and HMDA Data file, read geographic application and origination heat map 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 HMDA data-quality manager.

Recommendation