Assess whether HMDA data can be relied on for the exam (e62d78)

Situation

Model-risk partner for credit scoring owns HMDA data can be relied on inside a credit-card issuer changing line-assignment logic with HMDA LAR validity and quality edits as the only packet. A community complaint about appraisal gaps is what changed the clock for this Fair Lending CRA and Special-Purpose Programs file.

Decision

Model-risk partner for credit scoring 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 HMDA LAR validity and quality edits after a community complaint about appraisal gaps.

Hypotheses to test

• HMDA LAR validity and quality edits reads as Remove access or reverse the item once a community complaint about appraisal gaps is lined up to the same Fair Lending population.
• HMDA LAR validity and quality edits is closer to Temporary compensating control after a community complaint about appraisal gaps; Remove access or reverse the item would over-claim this CRA and Special-Purpose Programs extract.
• Approve a documented exception is still live in HMDA LAR validity and quality edits for model-risk partner for credit scoring in a credit-card issuer changing line-assignment logic.
• HMDA LAR validity and quality edits is missing the fact model-risk partner for credit scoring needs after a community complaint about appraisal gaps; stop this Fair Lending close.

Analysis required

• Test a documented exception versus a pattern a credit-card issuer changing line-assignment logic must defend.
• Match the adverse-action language to the facts in HMDA LAR validity and quality edits.
• Check HMDA coding and underwriting policy against HMDA data can be relied on.
• For this Fair Lending CRA and Special-Purpose Programs file, read HMDA LAR validity and quality edits against a community complaint about appraisal gaps and write the one fact that would move HMDA data can be relied on for model-risk partner for credit scoring.

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 (HMDA LAR validity and quality edits after a community complaint about appraisal gaps). If HMDA LAR validity and quality edits cannot force a Fair Lending label under CRA and Special-Purpose Programs, stop. If HMDA LAR validity and quality edits after a community complaint about appraisal gaps cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending CRA and Special-Purpose Programs close, model-risk partner for credit scoring must do not infer a control or scheme beyond the transaction and entitlement evidence.