Assess whether comparative files show second-review bias (406c51)

Situation

HMDA data-quality manager owns comparative files show second-review inside a small-business desk using a new vendor score with SPCP written plan versus actual originations as the only packet. A notice that cites 'other' as the principal reason 40% of the time is what changed the clock for this Fair Lending Examination and Notices file.

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 SPCP written plan versus actual originations after a notice that cites 'other' as the principal reason 40% of the time.

Hypotheses to test

• SPCP written plan versus actual originations reads as Remove access or reverse the item once a notice that cites 'other' as the principal reason 40% of the time is lined up to the same Fair Lending population.
• SPCP written plan versus actual originations is closer to Temporary compensating control after a notice that cites 'other' as the principal reason 40% of the time; Remove access or reverse the item would over-claim this Examination and Notices extract.
• Approve a documented exception is still live in SPCP written plan versus actual originations for HMDA data-quality manager in a small-business desk using a new vendor score.
• SPCP written plan versus actual originations is missing the fact HMDA data-quality manager needs after a notice that cites 'other' as the principal reason 40% of the time; stop this Fair Lending close.

Analysis required

• Match the adverse-action language to the facts in SPCP written plan versus actual originations.
• Check HMDA coding and underwriting policy against comparative files show second-review.
• Compare SPCP written plan versus actual originations to similarly situated files, second-review notes, and reason codes after a notice that cites 'other' as the principal reason 40% of the time.
• For this Fair Lending Examination and Notices file, read SPCP written plan versus actual originations against a notice that cites 'other' as the principal reason 40% of the time and write the one fact that would move comparative files show second-review for HMDA data-quality manager.

Recommendation