Assess whether HMDA data can be relied on for the exam after a community

Situation

Pricing and Credit Limits work in a small-business desk using a new vendor score now turns on HMDA data can be relied on because a community complaint about appraisal gaps put mortgage pricing residual by prohibited-basis group in play. Model-risk partner for credit scoring should say what mortgage pricing residual by prohibited-basis group proves.

Decision

Model-risk partner for credit scoring in a small-business desk using a new vendor score must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using mortgage pricing residual by prohibited-basis group after a community complaint about appraisal gaps.

Hypotheses to test

• A community complaint about appraisal gaps is noise around an already-controlled Pricing and Credit Limits process in a small-business desk using a new vendor score, given mortgage pricing residual by prohibited-basis group.
• A community complaint about appraisal gaps is the event in mortgage pricing residual by prohibited-basis group that forces Remove access or reverse the item for model-risk partner for credit scoring under Fair Lending.
• Mortgage pricing residual by prohibited-basis group shows a one-file miss after a community complaint about appraisal gaps, not a Pricing and Credit Limits program failure.
• Mortgage pricing residual by prohibited-basis group cannot decide HMDA data can be relied on yet after a community complaint about appraisal gaps; hold is the only Fair Lending close a small-business desk using a new vendor score can defend.

Analysis required

• Flag any disparate-impact table model-risk partner for credit scoring cannot explain from mortgage pricing residual by prohibited-basis group.
• Test a documented exception versus a pattern a small-business desk using a new vendor score must defend.
• Match the adverse-action language to the facts in mortgage pricing residual by prohibited-basis group.
• For this Fair Lending Pricing and Credit Limits file, read mortgage pricing residual by prohibited-basis group against a community complaint about appraisal gaps and write the one fact that would move HMDA data can be relied on for model-risk partner for credit scoring.

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 (mortgage pricing residual by prohibited-basis group after a community complaint about appraisal gaps). Lead with the Fair Lending option mortgage pricing residual by prohibited-basis group can support after a community complaint about appraisal gaps, then the two facts that force it, then the Monday action for model-risk partner for credit scoring in a small-business desk using a new vendor score.