Assess whether a model update needs a fair-lending revalidation (08bfcf)

Situation

Second-review underwriter owns a model update needs inside a small-business desk using a new vendor score with underwriting exception log by branch as the only packet. A DOJ or CFPB monitor request for pricing files is what changed the clock for this Fair Lending Redlining and HMDA Data file.

Decision

Second-review underwriter in a small-business desk using a new vendor score must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using underwriting exception log by branch after a DOJ or CFPB monitor request for pricing files.

Hypotheses to test

• The population in underwriting exception log by branch is the one a DOJ or CFPB monitor request for pricing files named, so Remove access or reverse the item follows for this Redlining and HMDA Data file.
• The population in underwriting exception log by branch is adjacent only to a DOJ or CFPB monitor request for pricing files; Temporary compensating control is the honest Fair Lending call.
• A small-business desk using a new vendor score already contained a DOJ or CFPB monitor request for pricing files before underwriting exception log by branch arrived; no new Redlining and HMDA Data path.
• Provenance on underwriting exception log by branch after a DOJ or CFPB monitor request for pricing files is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• 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 DOJ or CFPB monitor request for pricing files.
• Flag any disparate-impact table second-review underwriter cannot explain from underwriting exception log by branch.
• For this Fair Lending Redlining and HMDA Data file, read underwriting exception log by branch against a DOJ or CFPB monitor request for pricing files and write the one fact that would move a model update needs for second-review underwriter.

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 (underwriting exception log by branch after a DOJ or CFPB monitor request for pricing files). The follow-on Redlining and HMDA Data action is what second-review underwriter does next: implement the option, assign an owner, and log the missing fact.