Assess whether the exam response should concede a finding (089191)

SITUATION Model-reason-code mapping that does not match notices arrived with a vendor score change with no disparate-impact test for HMDA data-quality manager. That is a Fair Lending Examination and Notices decision on the exam response should in a small-business desk using a new vendor score.

DECISION HMDA data-quality manager 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 model-reason-code mapping that does not match notices after a vendor score change with no disparate-impact test.

HYPOTHESES TO TEST 1. Model-reason-code mapping that does not match notices reads as Remove access or reverse the item once a vendor score change with no disparate-impact test is lined up to the same Fair Lending population. 2. Model-reason-code mapping that does not match notices is closer to Temporary compensating control after a vendor score change with no disparate-impact test; Remove access or reverse the item would over-claim this Examination and Notices extract. 3. Approve a documented exception is still live in model-reason-code mapping that does not match notices for HMDA data-quality manager in a small-business desk using a new vendor score. 4. Model-reason-code mapping that does not match notices is missing the fact HMDA data-quality manager needs after a vendor score change with no disparate-impact test; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern a small-business desk using a new vendor score must defend. 2. Match the adverse-action language to the facts in model-reason-code mapping that does not match notices. 3. Check HMDA coding and underwriting policy against the exam response should. 4. For this Fair Lending Examination and Notices file, read model-reason-code mapping that does not match notices against a vendor score change with no disparate-impact test and write the one fact that would move the exam response should for HMDA data-quality manager.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Examination and Notices packet (model-reason-code mapping that does not match notices after a vendor score change with no disparate-impact test). Lead with the Fair Lending option model-reason-code mapping that does not match notices can support after a vendor score change with no disparate-impact test, then the two facts that force it, then the Monday action for HMDA data-quality manager in a small-business desk using a new vendor score.

COMMAND RETURNS - Bottom-line Fair Lending option on the exam response should, then the evidence in model-reason-code mapping that does not match notices, then the action for HMDA data-quality manager - Hypothesis scorecard against model-reason-code mapping that does not match notices: supported / rejected / untestable - Missing page in model-reason-code mapping that does not match notices after a vendor score change with no disparate-impact test, if any - Regulatory or exam hook Examination and Notices would cite