Assess whether a model update needs a fair-lending revalidation (a2f7e8)

Situation

A branch that stopped taking applications in one ZIP put underwriting exception log by branch in front of model-risk partner for credit scoring in a lender expanding into majority-minority census tracts. This Fair Lending / Examination and Notices close is a model update needs from underwriting exception log by branch, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

Decision

Model-risk partner for credit scoring in a lender expanding into majority-minority census tracts must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using underwriting exception log by branch after a branch that stopped taking applications in one ZIP.

Hypotheses to test

• Authorize Remove access or reverse the item now; underwriting exception log by branch already has the discriminator after a branch that stopped taking applications in one ZIP.
• Keep Temporary compensating control in force until underwriting exception log by branch is completed after a branch that stopped taking applications in one ZIP for model-risk partner for credit scoring.
• Treat underwriting exception log by branch as Approve a documented exception because both readings appear after a branch that stopped taking applications in one ZIP.
• Refuse a Fair Lending close: model-risk partner for credit scoring does not have the page a model update needs turns on in underwriting exception log by branch.

Analysis required

• Match the adverse-action language to the facts in underwriting exception log by branch.
• Check HMDA coding and underwriting policy against a model update needs.
• Compare underwriting exception log by branch to similarly situated files, second-review notes, and reason codes after a branch that stopped taking applications in one ZIP.
• For this Fair Lending Examination and Notices file, read underwriting exception log by branch against a branch that stopped taking applications in one ZIP and write the one fact that would move a model update needs for model-risk partner for credit scoring.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Examination and Notices packet (underwriting exception log by branch after a branch that stopped taking applications in one ZIP). Lead with the Fair Lending option underwriting exception log by branch can support after a branch that stopped taking applications in one ZIP, then the two facts that force it, then the Monday action for model-risk partner for credit scoring in a lender expanding into majority-minority census tracts.