Assess whether a model update needs a fair-lending revalidation (1af2df)

Situation

CRA strategist in a mortgage company after a pricing-regression spike has one working extract — HMDA LAR validity and quality edits — after a DOJ or CFPB monitor request for pricing files. If HMDA LAR validity and quality edits cannot support a model update needs, the honest Fair Lending output is hold.

Decision

CRA strategist in a mortgage company after a pricing-regression spike must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using HMDA LAR validity and quality edits after a DOJ or CFPB monitor request for pricing files.

Hypotheses to test

• CRA strategist can defend Remove access or reverse the item from HMDA LAR validity and quality edits after a DOJ or CFPB monitor request for pricing files in a Fair Lending challenge.
• CRA strategist cannot defend Remove access or reverse the item from HMDA LAR validity and quality edits; Temporary compensating control is what the extract actually supports after a DOJ or CFPB monitor request for pricing files.
• A DOJ or CFPB monitor request for pricing files never reached the population in HMDA LAR validity and quality edits — reopen intake, do not close a model update needs.
• Two facts in HMDA LAR validity and quality edits after a DOJ or CFPB monitor request for pricing files conflict for CRA strategist; hold this CRA and Special-Purpose Programs file.

Analysis required

• Compare HMDA LAR validity and quality edits 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 CRA strategist cannot explain from HMDA LAR validity and quality edits.
• Test a documented exception versus a pattern a mortgage company after a pricing-regression spike must defend.
• For this Fair Lending CRA and Special-Purpose Programs file, read HMDA LAR validity and quality edits against a DOJ or CFPB monitor request for pricing files 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 / CRA and Special-Purpose Programs packet (HMDA LAR validity and quality edits after a DOJ or CFPB monitor request for pricing files). The follow-on CRA and Special-Purpose Programs action is what CRA strategist does next: implement the option, assign an owner, and log the missing fact.