HMDA data-quality manager must resolve whether HMDA data can be relied on

Situation

Redlining and HMDA Data work in a credit-card issuer changing line-assignment logic now turns on HMDA data can be relied on because a HMDA resubmission that still fails quality edits put geographic application and origination heat map in play. HMDA data-quality manager should say what geographic application and origination heat map proves.

Decision

HMDA data-quality manager in a credit-card issuer changing line-assignment logic must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using geographic application and origination heat map after a HMDA resubmission that still fails quality edits.

Hypotheses to test

• Authorize Remove access or reverse the item now; geographic application and origination heat map already has the discriminator after a HMDA resubmission that still fails quality edits.
• Keep Temporary compensating control in force until geographic application and origination heat map is completed after a HMDA resubmission that still fails quality edits for HMDA data-quality manager.
• Treat geographic application and origination heat map as Approve a documented exception because both readings appear after a HMDA resubmission that still fails quality edits.
• Refuse a Fair Lending close: HMDA data-quality manager does not have the page HMDA data can be relied on turns on in geographic application and origination heat map.

Analysis required

• Check HMDA coding and underwriting policy against HMDA data can be relied on.
• Compare geographic application and origination heat map to similarly situated files, second-review notes, and reason codes after a HMDA resubmission that still fails quality edits.
• Flag any disparate-impact table HMDA data-quality manager cannot explain from geographic application and origination heat map.
• For this Fair Lending Redlining and HMDA Data file, read geographic application and origination heat map against a HMDA resubmission that still fails quality edits and write the one fact that would move HMDA data can be relied on 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 / Redlining and HMDA Data packet (geographic application and origination heat map after a HMDA resubmission that still fails quality edits). Lead with the Fair Lending option geographic application and origination heat map can support after a HMDA resubmission that still fails quality edits, then the two facts that force it, then the Monday action for HMDA data-quality manager in a credit-card issuer changing line-assignment logic.