Assess whether HMDA data can be relied on for the exam from SPCP written plan

Situation

Pricing and Credit Limits work in a credit-card issuer changing line-assignment logic now turns on HMDA data can be relied on because a vendor score change with no disparate-impact test put SPCP written plan versus actual originations in play. Second-review underwriter should say what SPCP written plan versus actual originations proves.

Decision

Second-review underwriter 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 SPCP written plan versus actual originations after a vendor score change with no disparate-impact test.

Hypotheses to test

• Authorize Remove access or reverse the item now; SPCP written plan versus actual originations already has the discriminator after a vendor score change with no disparate-impact test.
• Keep Temporary compensating control in force until SPCP written plan versus actual originations is completed after a vendor score change with no disparate-impact test for second-review underwriter.
• Treat SPCP written plan versus actual originations as Approve a documented exception because both readings appear after a vendor score change with no disparate-impact test.
• Refuse a Fair Lending close: second-review underwriter does not have the page HMDA data can be relied on turns on in SPCP written plan versus actual originations.

Analysis required

• Match the adverse-action language to the facts in SPCP written plan versus actual originations.
• Check HMDA coding and underwriting policy against HMDA data can be relied on.
• Compare SPCP written plan versus actual originations to similarly situated files, second-review notes, and reason codes after a vendor score change with no disparate-impact test.
• For this Fair Lending Pricing and Credit Limits file, read SPCP written plan versus actual originations 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 second-review underwriter.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Pricing and Credit Limits packet (SPCP written plan versus actual originations after a vendor score change with no disparate-impact test). Lead with the Fair Lending option SPCP written plan versus actual originations can support after a vendor score change with no disparate-impact test, then the two facts that force it, then the Monday action for second-review underwriter in a credit-card issuer changing line-assignment logic.