Assess whether HMDA data can be relied on for the exam from model-reason-code

Situation

Model-reason-code mapping that does not match notices arrived with a notice that cites 'other' as the principal reason 40% of the time for fair-lending officer. That is a Fair Lending Pricing and Credit Limits decision on HMDA data can be relied on in a mortgage company after a pricing-regression spike.

Decision

Fair-lending officer 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 model-reason-code mapping that does not match notices after a notice that cites 'other' as the principal reason 40% of the time.

Hypotheses to test

• Authorize Remove access or reverse the item now; model-reason-code mapping that does not match notices already has the discriminator after a notice that cites 'other' as the principal reason 40% of the time.
• Keep Temporary compensating control in force until model-reason-code mapping that does not match notices is completed after a notice that cites 'other' as the principal reason 40% of the time for fair-lending officer.
• Treat model-reason-code mapping that does not match notices as Approve a documented exception because both readings appear after a notice that cites 'other' as the principal reason 40% of the time.
• Refuse a Fair Lending close: fair-lending officer does not have the page HMDA data can be relied on turns on in model-reason-code mapping that does not match notices.

Analysis required

• Compare model-reason-code mapping that does not match notices to similarly situated files, second-review notes, and reason codes after a notice that cites 'other' as the principal reason 40% of the time.
• Flag any disparate-impact table fair-lending officer cannot explain from model-reason-code mapping that does not match notices.
• Test a documented exception versus a pattern a mortgage company after a pricing-regression spike must defend.
• For this Fair Lending Pricing and Credit Limits file, read model-reason-code mapping that does not match notices against a notice that cites 'other' as the principal reason 40% of the time and write the one fact that would move HMDA data can be relied on for fair-lending officer.

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 (model-reason-code mapping that does not match notices after a notice that cites 'other' as the principal reason 40% of the time). The follow-on Pricing and Credit Limits action is what fair-lending officer does next: implement the option, assign an owner, and log the missing fact.