Assess whether HMDA data can be relied on for the exam (239b68)

Situation

Adverse-action notice operations lead owns HMDA data can be relied on inside a small-business desk using a new vendor score with credit-card limit assignment disparity table as the only packet. An underwriter chat that used coded language is what changed the clock for this Fair Lending CRA and Special-Purpose Programs file.

Decision

Adverse-action notice operations lead 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 credit-card limit assignment disparity table after an underwriter chat that used coded language.

Hypotheses to test

• Adverse-action notice operations lead can defend Remove access or reverse the item from credit-card limit assignment disparity table after an underwriter chat that used coded language in a Fair Lending challenge.
• Adverse-action notice operations lead cannot defend Remove access or reverse the item from credit-card limit assignment disparity table; Temporary compensating control is what the extract actually supports after an underwriter chat that used coded language.
• An underwriter chat that used coded language never reached the population in credit-card limit assignment disparity table — reopen intake, do not close HMDA data can be relied on.
• Two facts in credit-card limit assignment disparity table after an underwriter chat that used coded language conflict for adverse-action notice operations lead; hold this CRA and Special-Purpose Programs file.

Analysis required

• Flag any disparate-impact table adverse-action notice operations lead cannot explain from credit-card limit assignment disparity table.
• Test a documented exception versus a pattern a small-business desk using a new vendor score must defend.
• Match the adverse-action language to the facts in credit-card limit assignment disparity table.
• For this Fair Lending CRA and Special-Purpose Programs file, read credit-card limit assignment disparity table against an underwriter chat that used coded language and write the one fact that would move HMDA data can be relied on for adverse-action notice operations lead.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / CRA and Special-Purpose Programs packet (credit-card limit assignment disparity table after an underwriter chat that used coded language). The follow-on CRA and Special-Purpose Programs action is what adverse-action notice operations lead does next: implement the option, assign an owner, and log the missing fact.