Assess whether HMDA data can be relied on for the exam (aa835d)

Situation

In a mortgage company after a pricing-regression spike, credit-card limit assignment disparity table is the evidence after a vendor score change with no disparate-impact test. Community-development lender has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending Redlining and HMDA Data close using credit-card limit assignment disparity table.

Decision

Community-development lender in a mortgage company after a pricing-regression spike must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using credit-card limit assignment disparity table after a vendor score change with no disparate-impact test.

Hypotheses to test

• Credit-card limit assignment disparity table reads as Remove access or reverse the item once a vendor score change with no disparate-impact test is lined up to the same Fair Lending population.
• Credit-card limit assignment disparity table is closer to Temporary compensating control after a vendor score change with no disparate-impact test; Remove access or reverse the item would over-claim this Redlining and HMDA Data extract.
• Approve a documented exception is still live in credit-card limit assignment disparity table for community-development lender in a mortgage company after a pricing-regression spike.
• Credit-card limit assignment disparity table is missing the fact community-development lender needs after a vendor score change with no disparate-impact test; stop this Fair Lending close.

Analysis required

• Flag any disparate-impact table community-development lender cannot explain from credit-card limit assignment disparity table.
• Test a documented exception versus a pattern a mortgage company after a pricing-regression spike must defend.
• Match the adverse-action language to the facts in credit-card limit assignment disparity table.
• For this Fair Lending Redlining and HMDA Data file, read credit-card limit assignment disparity table against a vendor score change with no disparate-impact test and write the one fact that would move HMDA data can be relied on for community-development lender.

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 (credit-card limit assignment disparity table after a vendor score change with no disparate-impact test). Lead with the Fair Lending option credit-card limit assignment disparity table can support after a vendor score change with no disparate-impact test, then the two facts that force it, then the Monday action for community-development lender in a mortgage company after a pricing-regression spike.