Assess whether a model update needs a fair-lending revalidation (75dff9)

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 community complaint about appraisal gaps 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 community complaint about appraisal gaps.

Hypotheses to test

• Authorize Remove access or reverse the item now; SPCP written plan versus actual originations already has the discriminator after a community complaint about appraisal gaps.
• Keep Temporary compensating control in force until SPCP written plan versus actual originations is completed after a community complaint about appraisal gaps for CRA strategist.
• Treat SPCP written plan versus actual originations as Approve a documented exception because both readings appear after a community complaint about appraisal gaps.
• Refuse a Fair Lending close: CRA strategist does not have the page a model update needs turns on in SPCP written plan versus actual originations.

Analysis required

• Check HMDA coding and underwriting policy against a model update needs.
• Compare SPCP written plan versus actual originations to similarly situated files, second-review notes, and reason codes after a community complaint about appraisal gaps.
• Flag any disparate-impact table CRA strategist cannot explain from SPCP written plan versus actual originations.
• For this Fair Lending Examination and Notices file, read SPCP written plan versus actual originations against a community complaint about appraisal gaps 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 community complaint about appraisal gaps). Lead with the Fair Lending option SPCP written plan versus actual originations can support after a community complaint about appraisal gaps, then the two facts that force it, then the Monday action for CRA strategist in a bank with thin HMDA LAR quality.