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

Situation

A special-purpose program is sits with model-risk partner for credit scoring because a HMDA resubmission that still fails quality edits hit a credit union rolling out a special-purpose credit program. Evidence is manufactured-housing dealer overlay notes; write the Fair Lending Redlining and HMDA Data option that extract can carry.

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 manufactured-housing dealer overlay notes 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 credit union rolling out a special-purpose credit program, given manufactured-housing dealer overlay notes.
• A HMDA resubmission that still fails quality edits is the event in manufactured-housing dealer overlay notes that forces A special-purpose program is well designed for model-risk partner for credit scoring under Fair Lending.
• Manufactured-housing dealer overlay notes shows a one-file miss after a HMDA resubmission that still fails quality edits, not a Redlining and HMDA Data program failure.
• Manufactured-housing dealer overlay notes cannot decide a special-purpose program is yet after a HMDA resubmission that still fails quality edits; hold is the only Fair Lending close a credit union rolling out a special-purpose credit program can defend.

Analysis required

• Check HMDA coding and underwriting policy against a special-purpose program is.
• Compare manufactured-housing dealer overlay notes to similarly situated files, second-review notes, and reason codes after a HMDA resubmission that still fails quality edits.
• Flag any disparate-impact table model-risk partner for credit scoring cannot explain from manufactured-housing dealer overlay notes.
• For this Fair Lending Redlining and HMDA Data file, read manufactured-housing dealer overlay notes against a HMDA resubmission that still fails quality edits 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 (manufactured-housing dealer overlay notes after a HMDA resubmission that still fails quality edits). Lead with the Fair Lending option manufactured-housing dealer overlay notes can support after a HMDA resubmission that still fails quality edits, then the two facts that force it, then the Monday action for model-risk partner for credit scoring in a credit union rolling out a special-purpose credit program.