Assess whether line assignments have a disparate impact the bank will defend

Situation

In a lender expanding into majority-minority census tracts, mortgage pricing residual by prohibited-basis group is the evidence after a HMDA resubmission that still fails quality edits. Model-risk partner for credit scoring has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending Examination and Notices close using mortgage pricing residual by prohibited-basis group.

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 mortgage pricing residual by prohibited-basis group after a HMDA resubmission that still fails quality edits.

Hypotheses to test

• The population in mortgage pricing residual by prohibited-basis group is the one a HMDA resubmission that still fails quality edits named, so Remove access or reverse the item follows for this Examination and Notices file.
• The population in mortgage pricing residual by prohibited-basis group is adjacent only to a HMDA resubmission that still fails quality edits; Temporary compensating control is the honest Fair Lending call.
• A lender expanding into majority-minority census tracts already contained a HMDA resubmission that still fails quality edits before mortgage pricing residual by prohibited-basis group arrived; no new Examination and Notices path.
• Provenance on mortgage pricing residual by prohibited-basis group after a HMDA resubmission that still fails quality edits is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Test a documented exception versus a pattern a lender expanding into majority-minority census tracts must defend.
• Match the adverse-action language to the facts in mortgage pricing residual by prohibited-basis group.
• Check HMDA coding and underwriting policy against line assignments have a.
• For this Fair Lending Examination and Notices file, read mortgage pricing residual by prohibited-basis group against a HMDA resubmission that still fails quality edits and write the one fact that would move line assignments have a for model-risk partner for credit scoring.

Recommendation