Assess whether a model update needs a fair-lending revalidation (0ddecb)

Situation

After an underwriter chat that used coded language, manufactured-housing dealer overlay notes is what fair-lending officer 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 Redlining and HMDA Data file.

Decision

Fair-lending officer 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 manufactured-housing dealer overlay notes after an underwriter chat that used coded language.

Hypotheses to test

• Fair-lending officer can defend Remove access or reverse the item from manufactured-housing dealer overlay notes after an underwriter chat that used coded language in a Fair Lending challenge.
• Fair-lending officer cannot defend Remove access or reverse the item from manufactured-housing dealer overlay notes; Temporary compensating control is what the extract actually supports after an underwriter chat that used coded language.
• An underwriter chat that used coded language never reached the population in manufactured-housing dealer overlay notes — reopen intake, do not close a model update needs.
• Two facts in manufactured-housing dealer overlay notes after an underwriter chat that used coded language conflict for fair-lending officer; hold this Redlining and HMDA Data file.

Analysis required

• Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend.
• Match the adverse-action language to the facts in manufactured-housing dealer overlay notes.
• Check HMDA coding and underwriting policy against a model update needs.
• For this Fair Lending Redlining and HMDA Data file, read manufactured-housing dealer overlay notes against an underwriter chat that used coded language and write the one fact that would move a model update needs for fair-lending officer.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Redlining and HMDA Data packet (manufactured-housing dealer overlay notes after an underwriter chat that used coded language). The follow-on Redlining and HMDA Data action is what fair-lending officer does next: implement the option, assign an owner, and log the missing fact.