Whether notices match the actual decisioning reasons from small-business

Situation

Pricing and Credit Limits work in a bank with thin HMDA LAR quality now turns on notices match the actual because a HMDA resubmission that still fails quality edits put small-business decline comparative file set in play. Community-development lender should say what small-business decline comparative file set proves.

Decision

Community-development lender 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 small-business decline comparative file set after a HMDA resubmission that still fails quality edits.

Hypotheses to test

• Small-business decline comparative file set reads as Remove access or reverse the item once a HMDA resubmission that still fails quality edits is lined up to the same Fair Lending population.
• Small-business decline comparative file set is closer to Temporary compensating control after a HMDA resubmission that still fails quality edits; Remove access or reverse the item would over-claim this Pricing and Credit Limits extract.
• Approve a documented exception is still live in small-business decline comparative file set for community-development lender in a bank with thin HMDA LAR quality.
• Small-business decline comparative file set is missing the fact community-development lender needs after a HMDA resubmission that still fails quality edits; stop this Fair Lending close.

Analysis required

• Compare small-business decline comparative file set to similarly situated files, second-review notes, and reason codes after a HMDA resubmission that still fails quality edits.
• Flag any disparate-impact table community-development lender cannot explain from small-business decline comparative file set.
• Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend.
• For this Fair Lending Pricing and Credit Limits file, read small-business decline comparative file set against a HMDA resubmission that still fails quality edits and write the one fact that would move notices match the actual for community-development lender.

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 (small-business decline comparative file set after a HMDA resubmission that still fails quality edits). If small-business decline comparative file set cannot force a Fair Lending label under Pricing and Credit Limits, stop. Do not invent pages a bank with thin HMDA LAR quality does not have.