Assess whether comparative files show second-review bias (61928a)

Situation

HMDA data-quality manager in a credit union rolling out a special-purpose credit program has one working extract — small-business decline comparative file set — after a vendor score change with no disparate-impact test. HMDA data-quality manager in a credit union rolling out a special-purpose credit program has small-business decline comparative file set after a vendor score change with no disparate-impact test. If that extract cannot support comparative files show second-review, the honest Fair Lending CRA and Special-Purpose Programs output is hold.

Decision

HMDA data-quality manager in a credit union rolling out a special-purpose credit program must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using small-business decline comparative file set after a vendor score change with no disparate-impact test.

Hypotheses to test

• HMDA data-quality manager can defend Remove access or reverse the item from small-business decline comparative file set after a vendor score change with no disparate-impact test in a Fair Lending challenge.
• HMDA data-quality manager cannot defend Remove access or reverse the item from small-business decline comparative file set; Temporary compensating control is what the extract actually supports after a vendor score change with no disparate-impact test.
• A vendor score change with no disparate-impact test never reached the population in small-business decline comparative file set — reopen intake, do not close comparative files show second-review.
• Two facts in small-business decline comparative file set after a vendor score change with no disparate-impact test conflict for HMDA data-quality manager; hold this CRA and Special-Purpose Programs file.

Analysis required

• Test a documented exception versus a pattern a credit union rolling out a special-purpose credit program must defend.
• Match the adverse-action language to the facts in small-business decline comparative file set.
• Check HMDA coding and underwriting policy against comparative files show second-review.
• For this Fair Lending CRA and Special-Purpose Programs file, read small-business decline comparative file set against a vendor score change with no disparate-impact test and write the one fact that would move comparative files show second-review for HMDA data-quality manager.