Assess whether HMDA data can be relied on for the exam (d37a09)

Situation

In a mortgage company after a pricing-regression spike, model-reason-code mapping that does not match notices is the evidence after a vendor score change with no disparate-impact test. CRA strategist has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending CRA and Special-Purpose Programs close using model-reason-code mapping that does not match notices.

Decision

CRA strategist 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 vendor score change with no disparate-impact test.

Hypotheses to test

• The population in model-reason-code mapping that does not match notices is the one a vendor score change with no disparate-impact test named, so Remove access or reverse the item follows for this CRA and Special-Purpose Programs file.
• The population in model-reason-code mapping that does not match notices is adjacent only to a vendor score change with no disparate-impact test; Temporary compensating control is the honest Fair Lending call.
• A mortgage company after a pricing-regression spike already contained a vendor score change with no disparate-impact test before model-reason-code mapping that does not match notices arrived; no new CRA and Special-Purpose Programs path.
• Provenance on model-reason-code mapping that does not match notices after a vendor score change with no disparate-impact test is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Compare model-reason-code mapping that does not match notices to similarly situated files, second-review notes, and reason codes after a vendor score change with no disparate-impact test.
• Flag any disparate-impact table CRA strategist 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 CRA and Special-Purpose Programs file, read model-reason-code mapping that does not match notices against a vendor score change with no disparate-impact test and write the one fact that would move HMDA data can be relied on for CRA strategist.