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

Situation

A vendor score change with no disparate-impact test put underwriting exception log by branch in front of HMDA data-quality manager in a small-business desk using a new vendor score. This Fair Lending / Examination and Notices close is HMDA data can be relied on from underwriting exception log by branch, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

Decision

HMDA data-quality manager in a small-business desk using a new vendor score must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using underwriting exception log by branch after a vendor score change with no disparate-impact test.

Hypotheses to test

• HMDA data-quality manager can defend Remove access or reverse the item from underwriting exception log by branch after a vendor score change with no disparate-impact test in a Fair Lending challenge.
• HMDA data-quality manager cannot defend Remove access or reverse the item from underwriting exception log by branch; Temporary compensating control is what the extract actually supports after a vendor score change with no disparate-impact test.
• A vendor score change with no disparate-impact test never reached the population in underwriting exception log by branch — reopen intake, do not close HMDA data can be relied on.
• Two facts in underwriting exception log by branch after a vendor score change with no disparate-impact test conflict for HMDA data-quality manager; hold this Examination and Notices file.

Analysis required

• Match the adverse-action language to the facts in underwriting exception log by branch.
• Check HMDA coding and underwriting policy against HMDA data can be relied on.
• Compare underwriting exception log by branch to similarly situated files, second-review notes, and reason codes after a vendor score change with no disparate-impact test.
• For this Fair Lending Examination and Notices file, read underwriting exception log by branch 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 HMDA data-quality manager.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Examination and Notices packet (underwriting exception log by branch after a vendor score change with no disparate-impact test). Lead with the Fair Lending option underwriting exception log by branch can support after a vendor score change with no disparate-impact test, then the two facts that force it, then the Monday action for HMDA data-quality manager in a small-business desk using a new vendor score.