Assess whether comparative files show second-review bias (217362)

Situation

Comparative files show second-review sits with HMDA data-quality manager because a HMDA resubmission that still fails quality edits hit a small-business desk using a new vendor score. Evidence is mortgage pricing residual by prohibited-basis group; write the Fair Lending Examination and Notices option that extract can carry.

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 mortgage pricing residual by prohibited-basis group after a HMDA resubmission that still fails quality edits.

Hypotheses to test

• The population in mortgage pricing residual by prohibited-basis group is the one a HMDA resubmission that still fails quality edits named, so Remove access or reverse the item follows for this Examination and Notices file.
• The population in mortgage pricing residual by prohibited-basis group is adjacent only to a HMDA resubmission that still fails quality edits; Temporary compensating control is the honest Fair Lending call.
• A small-business desk using a new vendor score already contained a HMDA resubmission that still fails quality edits before mortgage pricing residual by prohibited-basis group arrived; no new Examination and Notices path.
• Provenance on mortgage pricing residual by prohibited-basis group after a HMDA resubmission that still fails quality edits is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Check HMDA coding and underwriting policy against comparative files show second-review.
• Compare mortgage pricing residual by prohibited-basis group to similarly situated files, second-review notes, and reason codes after a HMDA resubmission that still fails quality edits.
• Flag any disparate-impact table HMDA data-quality manager cannot explain from mortgage pricing residual by prohibited-basis group.
• For this Fair Lending Examination and Notices file, read mortgage pricing residual by prohibited-basis group against a HMDA resubmission that still fails quality edits and write the one fact that would move comparative files show second-review for HMDA data-quality manager.

Recommendation