Assess whether HMDA data can be relied on for the exam from HMDA LAR validity

Situation

Second-review underwriter in a credit-card issuer changing line-assignment logic has one working extract — HMDA LAR validity and quality edits — after a HMDA resubmission that still fails quality edits. If HMDA LAR validity and quality edits cannot support HMDA data can be relied on, the honest Fair Lending output is hold.

Decision

Second-review underwriter 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 HMDA LAR validity and quality edits after a HMDA resubmission that still fails quality edits.

Hypotheses to test

• The population in HMDA LAR validity and quality edits is the one a HMDA resubmission that still fails quality edits named, so Remove access or reverse the item follows for this Pricing and Credit Limits file.
• The population in HMDA LAR validity and quality edits is adjacent only to a HMDA resubmission that still fails quality edits; Temporary compensating control is the honest Fair Lending call.
• A credit-card issuer changing line-assignment logic already contained a HMDA resubmission that still fails quality edits before HMDA LAR validity and quality edits arrived; no new Pricing and Credit Limits path.
• Provenance on HMDA LAR validity and quality edits after a HMDA resubmission that still fails quality edits is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Test a documented exception versus a pattern a credit-card issuer changing line-assignment logic must defend.
• Match the adverse-action language to the facts in HMDA LAR validity and quality edits.
• Check HMDA coding and underwriting policy against HMDA data can be relied on.
• For this Fair Lending Pricing and Credit Limits file, read HMDA LAR validity and quality edits against a HMDA resubmission that still fails quality edits and write the one fact that would move HMDA data can be relied on for second-review underwriter.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Pricing and Credit Limits packet (HMDA LAR validity and quality edits after a HMDA resubmission that still fails quality edits). The follow-on Pricing and Credit Limits action is what second-review underwriter does next: implement the option, assign an owner, and log the missing fact.