Assess whether a model update needs a fair-lending revalidation (4f82bc)

Situation

A model update needs sits with fair-lending officer because a community complaint about appraisal gaps hit a manufactured-housing lender with dealer-originated files. Evidence is manufactured-housing dealer overlay notes; write the Fair Lending Redlining and HMDA Data option that extract can carry.

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 a community complaint about appraisal gaps.

Hypotheses to test

• Fair-lending officer can defend Remove access or reverse the item from manufactured-housing dealer overlay notes after a community complaint about appraisal gaps 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 a community complaint about appraisal gaps.
• A community complaint about appraisal gaps 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 a community complaint about appraisal gaps 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 a community complaint about appraisal gaps 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 a community complaint about appraisal gaps). Lead with the Fair Lending option manufactured-housing dealer overlay notes can support after a community complaint about appraisal gaps, then the two facts that force it, then the Monday action for fair-lending officer in a manufactured-housing lender with dealer-originated files.