Assess whether HMDA data can be relied on for the exam from adverse-action

Situation

In a mortgage company after a pricing-regression spike, adverse-action notice principal-reason sample is the evidence after a board asking if the bank should settle a matched-pair study. Fair-lending officer has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending Pricing and Credit Limits close using adverse-action notice principal-reason sample.

Decision

Fair-lending officer in a mortgage company after a pricing-regression spike must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using adverse-action notice principal-reason sample after a board asking if the bank should settle a matched-pair study.

Hypotheses to test

• A board asking if the bank should settle a matched-pair study is noise around an already-controlled Pricing and Credit Limits process in a mortgage company after a pricing-regression spike, given adverse-action notice principal-reason sample.
• A board asking if the bank should settle a matched-pair study is the event in adverse-action notice principal-reason sample that forces Remove access or reverse the item for fair-lending officer under Fair Lending.
• Adverse-action notice principal-reason sample shows a one-file miss after a board asking if the bank should settle a matched-pair study, not a Pricing and Credit Limits program failure.
• Adverse-action notice principal-reason sample cannot decide HMDA data can be relied on yet after a board asking if the bank should settle a matched-pair study; hold is the only Fair Lending close a mortgage company after a pricing-regression spike can defend.

Analysis required

• Compare adverse-action notice principal-reason sample to similarly situated files, second-review notes, and reason codes after a board asking if the bank should settle a matched-pair study.
• Flag any disparate-impact table fair-lending officer cannot explain from adverse-action notice principal-reason sample.
• Test a documented exception versus a pattern a mortgage company after a pricing-regression spike must defend.
• For this Fair Lending Pricing and Credit Limits file, read adverse-action notice principal-reason sample against a board asking if the bank should settle a matched-pair study and write the one fact that would move HMDA data can be relied on for fair-lending officer.