Assess whether notices match the actual decisioning reasons after a HMDA

SITUATION A credit union rolling out a special-purpose credit program cannot treat a HMDA resubmission that still fails quality edits as incidental context on HMDA LAR validity and quality edits. Model-risk partner for credit scoring must close notices match the actual from that extract under Fair Lending / Redlining and HMDA Data.

DECISION Model-risk partner for credit scoring 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 HMDA LAR validity and quality edits after a HMDA resubmission that still fails quality edits.

HYPOTHESES TO TEST 1. Model-risk partner for credit scoring can defend Remove access or reverse the item from HMDA LAR validity and quality edits after a HMDA resubmission that still fails quality edits in a Fair Lending challenge. 2. Model-risk partner for credit scoring cannot defend Remove access or reverse the item from HMDA LAR validity and quality edits; Temporary compensating control is what the extract actually supports after a HMDA resubmission that still fails quality edits. 3. A HMDA resubmission that still fails quality edits never reached the population in HMDA LAR validity and quality edits — reopen intake, do not close notices match the actual. 4. Two facts in HMDA LAR validity and quality edits after a HMDA resubmission that still fails quality edits conflict for model-risk partner for credit scoring; hold this Redlining and HMDA Data file.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against notices match the actual. 2. Compare HMDA LAR validity and quality edits to similarly situated files, second-review notes, and reason codes after a HMDA resubmission that still fails quality edits. 3. Flag any disparate-impact table model-risk partner for credit scoring cannot explain from HMDA LAR validity and quality edits. 4. For this Fair Lending Redlining and HMDA Data file, read HMDA LAR validity and quality edits against a HMDA resubmission that still fails quality edits and write the one fact that would move notices match the actual for model-risk partner for credit scoring.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Redlining and HMDA Data packet (HMDA LAR validity and quality edits after a HMDA resubmission that still fails quality edits). The follow-on Redlining and HMDA Data action is what model-risk partner for credit scoring does next: implement the option, assign an owner, and log the missing fact.

COMMAND RETURNS - Bottom-line Fair Lending option on notices match the actual, then the evidence in HMDA LAR validity and quality edits, then the action for model-risk partner for credit scoring - Hypothesis scorecard against HMDA LAR validity and quality edits: supported / rejected / untestable - Missing page in HMDA LAR validity and quality edits after a HMDA resubmission that still fails quality edits, if any - Regulatory or exam hook Redlining and HMDA Data would cite