Can This HMDA Data Be Relied on for the Exam?

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 HMDA resubmission that still fails quality edits put small-business decline comparative file set in play. Model-risk partner for credit scoring should say what small-business decline comparative file set 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 small-business decline comparative file set after a HMDA resubmission that still fails quality edits.

Hypotheses to test

• Authorize Remove access or reverse the item now; small-business decline comparative file set already has the discriminator after a HMDA resubmission that still fails quality edits.
• Keep Temporary compensating control in force until small-business decline comparative file set is completed after a HMDA resubmission that still fails quality edits for model-risk partner for credit scoring.
• Treat small-business decline comparative file set as Approve a documented exception because both readings appear after a HMDA resubmission that still fails quality edits.
• Refuse a Fair Lending close: model-risk partner for credit scoring does not have the page HMDA data can be relied on turns on in small-business decline comparative file set.

Analysis required

• Flag any disparate-impact table model-risk partner for credit scoring cannot explain from small-business decline comparative file set.
• 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 small-business decline comparative file set.
• For this Fair Lending Pricing and Credit Limits file, read small-business decline comparative file set against a HMDA resubmission that still fails quality edits 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 (small-business decline comparative file set after a HMDA resubmission that still fails quality edits). If small-business decline comparative file set cannot force a Fair Lending label under Pricing and Credit Limits, stop. Do not invent pages a small-business desk using a new vendor score does not have.