Assess whether a special-purpose program is well designed or a pretext

Situation

After an exception rate twice as high for one group after credit controls, HMDA LAR validity and quality edits is what model-risk partner for credit scoring can touch in a credit union rolling out a special-purpose credit program. Fair Lending will live with A special-purpose program is well designed versus A pretext on this Redlining and HMDA Data file.

Decision

Model-risk partner for credit scoring in a credit union rolling out a special-purpose credit program must choose A special-purpose program is well designed / A pretext using HMDA LAR validity and quality edits after an exception rate twice as high for one group after credit controls.

Hypotheses to test

• The population in HMDA LAR validity and quality edits is the one an exception rate twice as high for one group after credit controls named, so A special-purpose program is well designed follows for this Redlining and HMDA Data file.
• The population in HMDA LAR validity and quality edits is adjacent only to an exception rate twice as high for one group after credit controls; A pretext is the honest Fair Lending call.
• A credit union rolling out a special-purpose credit program already contained an exception rate twice as high for one group after credit controls before HMDA LAR validity and quality edits arrived; no new Redlining and HMDA Data path.
• Provenance on HMDA LAR validity and quality edits after an exception rate twice as high for one group after credit controls is broken; do not pick A special-purpose program is well designed or A pretext yet.

Analysis required

• Match the adverse-action language to the facts in HMDA LAR validity and quality edits.
• Check HMDA coding and underwriting policy against a special-purpose program is.
• Compare HMDA LAR validity and quality edits to similarly situated files, second-review notes, and reason codes after an exception rate twice as high for one group after credit controls.
• For this Fair Lending Redlining and HMDA Data file, read HMDA LAR validity and quality edits against an exception rate twice as high for one group after credit controls and write the one fact that would move a special-purpose program is for model-risk partner for credit scoring.

Recommendation

Choose A special-purpose program is well designed / A pretext on this Fair Lending / Redlining and HMDA Data packet (HMDA LAR validity and quality edits after an exception rate twice as high for one group after credit controls). 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.