Assess whether HMDA data can be relied on for the exam (bb7d71)

Situation

The desk packet is model-reason-code mapping that does not match notices after an underwriter chat that used coded language. Second-review underwriter in a credit union rolling out a special-purpose credit program has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending Examination and Notices file.

Decision

Second-review underwriter in a credit union rolling out a special-purpose credit program must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using model-reason-code mapping that does not match notices after an underwriter chat that used coded language.

Hypotheses to test

• Second-review underwriter can defend Remove access or reverse the item from model-reason-code mapping that does not match notices after an underwriter chat that used coded language in a Fair Lending challenge.
• Second-review underwriter cannot defend Remove access or reverse the item from model-reason-code mapping that does not match notices; 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 model-reason-code mapping that does not match notices — reopen intake, do not close HMDA data can be relied on.
• Two facts in model-reason-code mapping that does not match notices after an underwriter chat that used coded language conflict for second-review underwriter; hold this Examination and Notices file.

Analysis required

• Test a documented exception versus a pattern a credit union rolling out a special-purpose credit program must defend.
• Match the adverse-action language to the facts in model-reason-code mapping that does not match notices.
• Check HMDA coding and underwriting policy against HMDA data can be relied on.
• For this Fair Lending Examination and Notices file, read model-reason-code mapping that does not match notices against an underwriter chat that used coded language and write the one fact that would move HMDA data can be relied on for second-review underwriter.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Examination and Notices packet (model-reason-code mapping that does not match notices after an underwriter chat that used coded language). Lead with the Fair Lending option model-reason-code mapping that does not match notices can support after an underwriter chat that used coded language, then the two facts that force it, then the Monday action for second-review underwriter in a credit union rolling out a special-purpose credit program.