Assess whether HMDA data can be relied on for the exam after a board asking

Situation

Fair-lending officer owns HMDA data can be relied on inside a mortgage company after a pricing-regression spike with model-reason-code mapping that does not match notices 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 Pricing and Credit Limits file.

Decision

Fair-lending officer in a mortgage company after a pricing-regression spike 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 a board asking if the bank should settle a matched-pair study.

Hypotheses to test

• Model-reason-code mapping that does not match notices 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.
• Model-reason-code mapping that does not match notices 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 Pricing and Credit Limits extract.
• Approve a documented exception is still live in model-reason-code mapping that does not match notices for fair-lending officer in a mortgage company after a pricing-regression spike.
• Model-reason-code mapping that does not match notices is missing the fact fair-lending officer needs after a board asking if the bank should settle a matched-pair study; stop this Fair Lending close.

Analysis required

• Compare model-reason-code mapping that does not match notices 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 fair-lending officer cannot explain from model-reason-code mapping that does not match notices.
• Test a documented exception versus a pattern a mortgage company after a pricing-regression spike must defend.
• For this Fair Lending Pricing and Credit Limits file, read model-reason-code mapping that does not match notices 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 fair-lending officer.

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