Assess whether HMDA data can be relied on for the exam (8dc71e)

Situation

Model-risk partner for credit scoring owns HMDA data can be relied on inside a credit-card issuer changing line-assignment logic with manufactured-housing dealer overlay notes as the only packet. A board asking if the bank should settle a matched-pair study 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 manufactured-housing dealer overlay notes after a board asking if the bank should settle a matched-pair study.

Hypotheses to test

• Manufactured-housing dealer overlay notes reads as Remove access or reverse the item once a board asking if the bank should settle a matched-pair study is lined up to the same Fair Lending population.
• Manufactured-housing dealer overlay notes is closer to Temporary compensating control after a board asking if the bank should settle a matched-pair study; Remove access or reverse the item would over-claim this CRA and Special-Purpose Programs extract.
• Approve a documented exception is still live in manufactured-housing dealer overlay notes for model-risk partner for credit scoring in a credit-card issuer changing line-assignment logic.
• Manufactured-housing dealer overlay notes is missing the fact model-risk partner for credit scoring needs after a board asking if the bank should settle a matched-pair study; stop this Fair Lending close.

Analysis required

• Compare manufactured-housing dealer overlay notes 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 model-risk partner for credit scoring cannot explain from manufactured-housing dealer overlay notes.
• Test a documented exception versus a pattern a credit-card issuer changing line-assignment logic must defend.
• For this Fair Lending CRA and Special-Purpose Programs file, read manufactured-housing dealer overlay notes 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 model-risk partner for credit scoring.

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