Assess whether a redlining pattern exists after controls (61d2fb)

Situation

In a bank with thin HMDA LAR quality, model-reason-code mapping that does not match notices is the evidence after a HMDA resubmission that still fails quality edits. Exam-response coordinator has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending Redlining and HMDA Data close using model-reason-code mapping that does not match notices.

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 HMDA resubmission that still fails quality edits.

Hypotheses to test

• A HMDA resubmission that still fails quality edits is noise around an already-controlled Redlining and HMDA Data process in a bank with thin HMDA LAR quality, given model-reason-code mapping that does not match notices.
• A HMDA resubmission that still fails quality edits is the event in model-reason-code mapping that does not match notices that forces Remove access or reverse the item for exam-response coordinator under Fair Lending.
• Model-reason-code mapping that does not match notices shows a one-file miss after a HMDA resubmission that still fails quality edits, not a Redlining and HMDA Data program failure.
• Model-reason-code mapping that does not match notices cannot decide a redlining pattern exists yet after a HMDA resubmission that still fails quality edits; hold is the only Fair Lending close a bank with thin HMDA LAR quality can defend.

Analysis required

• Flag any disparate-impact table exam-response coordinator cannot explain from model-reason-code mapping that does not match notices.
• Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend.
• Match the adverse-action language to the facts in model-reason-code mapping that does not match notices.
• For this Fair Lending Redlining and HMDA Data file, read model-reason-code mapping that does not match notices against a HMDA resubmission that still fails quality edits and write the one fact that would move a redlining pattern exists 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 HMDA resubmission that still fails quality edits). 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.