Assess whether a redlining pattern exists after controls (fcbdda)

Situation

A SPCP that originated almost no loans to the intended class put credit-card limit assignment disparity table 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 a redlining pattern exists from credit-card limit assignment disparity table, 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 credit-card limit assignment disparity table after a SPCP that originated almost no loans to the intended class.

Hypotheses to test

• HMDA data-quality manager can defend Remove access or reverse the item from credit-card limit assignment disparity table after a SPCP that originated almost no loans to the intended class in a Fair Lending challenge.
• HMDA data-quality manager cannot defend Remove access or reverse the item from credit-card limit assignment disparity table; Temporary compensating control is what the extract actually supports after a SPCP that originated almost no loans to the intended class.
• A SPCP that originated almost no loans to the intended class never reached the population in credit-card limit assignment disparity table — reopen intake, do not close a redlining pattern exists.
• Two facts in credit-card limit assignment disparity table after a SPCP that originated almost no loans to the intended class conflict for HMDA data-quality manager; hold this Examination and Notices file.

Analysis required

• Test a documented exception versus a pattern a small-business desk using a new vendor score must defend.
• Match the adverse-action language to the facts in credit-card limit assignment disparity table.
• Check HMDA coding and underwriting policy against a redlining pattern exists.
• For this Fair Lending Examination and Notices file, read credit-card limit assignment disparity table against a SPCP that originated almost no loans to the intended class and write the one fact that would move a redlining pattern exists for HMDA data-quality manager.

Recommendation