HMDA data-quality manager must resolve whether comparative files show

Situation

After an exception rate twice as high for one group after credit controls, SPCP written plan versus actual originations is what HMDA data-quality manager can touch in a credit-card issuer changing line-assignment logic. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this Redlining and HMDA Data file.

Decision

HMDA data-quality manager in a credit-card issuer changing line-assignment logic must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using SPCP written plan versus actual originations after an exception rate twice as high for one group after credit controls.

Hypotheses to test

• SPCP written plan versus actual originations reads as Remove access or reverse the item once an exception rate twice as high for one group after credit controls is lined up to the same Fair Lending population.
• SPCP written plan versus actual originations is closer to Temporary compensating control after an exception rate twice as high for one group after credit controls; Remove access or reverse the item would over-claim this Redlining and HMDA Data extract.
• Approve a documented exception is still live in SPCP written plan versus actual originations for HMDA data-quality manager in a credit-card issuer changing line-assignment logic.
• SPCP written plan versus actual originations is missing the fact HMDA data-quality manager needs after an exception rate twice as high for one group after credit controls; stop this Fair Lending close.

Analysis required

• Compare SPCP written plan versus actual originations to similarly situated files, second-review notes, and reason codes after an exception rate twice as high for one group after credit controls.
• Flag any disparate-impact table HMDA data-quality manager cannot explain from SPCP written plan versus actual originations.
• Test a documented exception versus a pattern a credit-card issuer changing line-assignment logic must defend.
• For this Fair Lending Redlining and HMDA Data file, read SPCP written plan versus actual originations against an exception rate twice as high for one group after credit controls and write the one fact that would move comparative files show second-review for HMDA data-quality manager.

Recommendation