Assess whether notices match the actual decisioning reasons (977154)

SITUATION Examination and Notices work in a small-business desk using a new vendor score now turns on notices match the actual because a marketing mailer that skipped majority-minority tracts put geographic application and origination heat map in play. Examination and Notices work in a small-business desk using a new vendor score now turns on notices match the actual because a marketing mailer that skipped majority-minority tracts put geographic application and origination heat map in play; HMDA data-quality manager should say what geographic application and origination heat map proves for Fair Lending.

DECISION HMDA data-quality manager 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 geographic application and origination heat map after a marketing mailer that skipped majority-minority tracts.

HYPOTHESES TO TEST 1. A marketing mailer that skipped majority-minority tracts is noise around an already-controlled Examination and Notices process in a small-business desk using a new vendor score, given geographic application and origination heat map. 2. A marketing mailer that skipped majority-minority tracts is the event in geographic application and origination heat map that forces Remove access or reverse the item for HMDA data-quality manager under Fair Lending. 3. Geographic application and origination heat map shows a one-file miss after a marketing mailer that skipped majority-minority tracts, not a Examination and Notices program failure. 4. Geographic application and origination heat map cannot decide notices match the actual yet after a marketing mailer that skipped majority-minority tracts; hold is the only Fair Lending close a small-business desk using a new vendor score can defend.

ANALYSIS REQUIRED 1. Compare geographic application and origination heat map to similarly situated files, second-review notes, and reason codes after a marketing mailer that skipped majority-minority tracts. 2. Flag any disparate-impact table HMDA data-quality manager cannot explain from geographic application and origination heat map. 3. Test a documented exception versus a pattern a small-business desk using a new vendor score must defend. 4. For this Fair Lending Examination and Notices file, read geographic application and origination heat map against a marketing mailer that skipped majority-minority tracts and write the one fact that would move notices match the actual for HMDA data-quality manager.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Examination and Notices packet (geographic application and origination heat map after a marketing mailer that skipped majority-minority tracts). The follow-on Examination and Notices action is what HMDA data-quality manager does next: implement the option, assign an owner, and log the missing fact.