Assess whether a model update needs a fair-lending revalidation (c5902f)

Situation

After a community complaint about appraisal gaps, HMDA LAR validity and quality edits is what exam-response coordinator can touch in a manufactured-housing lender with dealer-originated files. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this CRA and Special-Purpose Programs file.

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 HMDA LAR validity and quality edits after a community complaint about appraisal gaps.

Hypotheses to test

• Exam-response coordinator can defend Remove access or reverse the item from HMDA LAR validity and quality edits after a community complaint about appraisal gaps in a Fair Lending challenge.
• Exam-response coordinator 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 community complaint about appraisal gaps.
• A community complaint about appraisal gaps 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 community complaint about appraisal gaps conflict for exam-response coordinator; 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 community complaint about appraisal gaps.
• Flag any disparate-impact table exam-response coordinator cannot explain from HMDA LAR validity and quality edits.
• Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend.
• For this Fair Lending CRA and Special-Purpose Programs file, read HMDA LAR validity and quality edits against a community complaint about appraisal gaps and write the one fact that would move a model update needs for exam-response coordinator.

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 community complaint about appraisal gaps). The follow-on CRA and Special-Purpose Programs action is what exam-response coordinator does next: implement the option, assign an owner, and log the missing fact.