Whether HMDA data can be relied on for the exam from underwriting exception

Situation

Second-review underwriter in a credit-card issuer changing line-assignment logic has one working extract — underwriting exception log by branch — after a HMDA resubmission that still fails quality edits. If underwriting exception log by branch 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 underwriting exception log by branch after a HMDA resubmission that still fails quality edits.

Hypotheses to test

• A HMDA resubmission that still fails quality edits is noise around an already-controlled Pricing and Credit Limits process in a credit-card issuer changing line-assignment logic, given underwriting exception log by branch.
• A HMDA resubmission that still fails quality edits is the event in underwriting exception log by branch that forces Remove access or reverse the item for second-review underwriter under Fair Lending.
• Underwriting exception log by branch shows a one-file miss after a HMDA resubmission that still fails quality edits, not a Pricing and Credit Limits program failure.
• Underwriting exception log by branch cannot decide HMDA data can be relied on yet after a HMDA resubmission that still fails quality edits; hold is the only Fair Lending close a credit-card issuer changing line-assignment logic can defend.

Analysis required

• Match the adverse-action language to the facts in underwriting exception log by branch.
• Check HMDA coding and underwriting policy against HMDA data can be relied on.
• Compare underwriting exception log by branch to similarly situated files, second-review notes, and reason codes after a HMDA resubmission that still fails quality edits.
• For this Fair Lending Pricing and Credit Limits file, read underwriting exception log by branch 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 (underwriting exception log by branch after a HMDA resubmission that still fails quality edits). If underwriting exception log by branch cannot force a Fair Lending label under Pricing and Credit Limits, stop. Do not invent pages a credit-card issuer changing line-assignment logic does not have.