Assess whether the exam response should concede a finding (d91a27)

SITUATION Small-business decline comparative file set arrived with a vendor score change with no disparate-impact test for HMDA data-quality manager. That is a Fair Lending Redlining and HMDA Data decision on the exam response should in a credit-card issuer changing line-assignment logic.

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 small-business decline comparative file set after a vendor score change with no disparate-impact test.

HYPOTHESES TO TEST 1. A vendor score change with no disparate-impact test is noise around an already-controlled Redlining and HMDA Data process in a credit-card issuer changing line-assignment logic, given small-business decline comparative file set. 2. A vendor score change with no disparate-impact test is the event in small-business decline comparative file set that forces Remove access or reverse the item for HMDA data-quality manager under Fair Lending. 3. Small-business decline comparative file set shows a one-file miss after a vendor score change with no disparate-impact test, not a Redlining and HMDA Data program failure. 4. Small-business decline comparative file set cannot decide the exam response should yet after a vendor score change with no disparate-impact test; hold is the only Fair Lending close a credit-card issuer changing line-assignment logic can defend.

ANALYSIS REQUIRED 1. Compare small-business decline comparative file set to similarly situated files, second-review notes, and reason codes after a vendor score change with no disparate-impact test. 2. Flag any disparate-impact table HMDA data-quality manager cannot explain from small-business decline comparative file set. 3. Test a documented exception versus a pattern a credit-card issuer changing line-assignment logic must defend. 4. For this Fair Lending Redlining and HMDA Data file, read small-business decline comparative file set against a vendor score change with no disparate-impact test and write the one fact that would move the exam response should for HMDA data-quality manager.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Redlining and HMDA Data packet (small-business decline comparative file set after a vendor score change with no disparate-impact test). The follow-on Redlining and HMDA Data action is what HMDA data-quality manager does next: implement the option, assign an owner, and log the missing fact.

COMMAND RETURNS - Bottom-line Fair Lending option on the exam response should, then the evidence in small-business decline comparative file set, then the action for HMDA data-quality manager - Hypothesis scorecard against small-business decline comparative file set: supported / rejected / untestable - Missing page in small-business decline comparative file set after a vendor score change with no disparate-impact test, if any - Regulatory or exam hook Redlining and HMDA Data would cite