Assess whether notices match the actual decisioning reasons (3477c2)

SITUATION A vendor score change with no disparate-impact test put model-reason-code mapping that does not match notices in front of exam-response coordinator in a bank with thin HMDA LAR quality. This Fair Lending / Redlining and HMDA Data close is notices match the actual from model-reason-code mapping that does not match notices, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

DECISION Exam-response coordinator in a bank with thin HMDA LAR quality 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 1. Authorize Remove access or reverse the item now; model-reason-code mapping that does not match notices already has the discriminator after a vendor score change with no disparate-impact test. 2. Keep Temporary compensating control in force until model-reason-code mapping that does not match notices is completed after a vendor score change with no disparate-impact test for exam-response coordinator. 3. Treat model-reason-code mapping that does not match notices as Approve a documented exception because both readings appear after a vendor score change with no disparate-impact test. 4. Refuse a Fair Lending close: exam-response coordinator does not have the decision notices match the actual turns on in model-reason-code mapping that does not match notices.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend. 2. Match the adverse-action language to the facts in model-reason-code mapping that does not match notices. 3. Check HMDA coding and underwriting policy against notices match the actual. 4. For this Fair Lending Redlining and HMDA Data 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 notices match the actual for exam-response coordinator.

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 (model-reason-code mapping that does not match notices after a vendor score change with no disparate-impact test). The follow-on Redlining and HMDA Data action is what exam-response coordinator 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 model-reason-code mapping that does not match notices, then the action for exam-response coordinator - Hypothesis scorecard against model-reason-code mapping that does not match notices: supported / rejected / untestable - Owner and next date for exam-response coordinator in a bank with thin HMDA LAR quality - What changes notices match the actual if a vendor score change with no disparate-impact test is later withdrawn