Assess whether notices match the actual decisioning reasons (d5f70f)

SITUATION Redlining and HMDA Data work in a credit union rolling out a special-purpose credit program now turns on notices match the actual because a notice that cites 'other' as the principal reason 40% of the time put HMDA LAR validity and quality edits in play. Model-risk partner for credit scoring should say what HMDA LAR validity and quality edits proves.

DECISION Model-risk partner for credit scoring in a credit union rolling out a special-purpose credit program must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using HMDA LAR validity and quality edits after a notice that cites 'other' as the principal reason 40% of the time.

HYPOTHESES TO TEST 1. The population in HMDA LAR validity and quality edits is the one a notice that cites 'other' as the principal reason 40% of the time named, so Remove access or reverse the item follows for this Redlining and HMDA Data file. 2. The population in HMDA LAR validity and quality edits is adjacent only to a notice that cites 'other' as the principal reason 40% of the time; Temporary compensating control is the honest Fair Lending call. 3. A credit union rolling out a special-purpose credit program already contained a notice that cites 'other' as the principal reason 40% of the time before HMDA LAR validity and quality edits arrived; no new Redlining and HMDA Data path. 4. Provenance on HMDA LAR validity and quality edits after a notice that cites 'other' as the principal reason 40% of the time is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

ANALYSIS REQUIRED 1. Flag any disparate-impact table model-risk partner for credit scoring cannot explain from HMDA LAR validity and quality edits. 2. Test a documented exception versus a pattern a credit union rolling out a special-purpose credit program must defend. 3. Match the adverse-action language to the facts in HMDA LAR validity and quality edits. 4. For this Fair Lending Redlining and HMDA Data file, read HMDA LAR validity and quality edits against a notice that cites 'other' as the principal reason 40% of the time and write the one fact that would move notices match the actual 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 / Redlining and HMDA Data packet (HMDA LAR validity and quality edits after a notice that cites 'other' as the principal reason 40% of the time). If HMDA LAR validity and quality edits cannot force a Fair Lending label under Redlining and HMDA Data, stop. If HMDA LAR validity and quality edits after a notice that cites 'other' as the principal reason 40% of the time cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending Redlining and HMDA Data close, model-risk partner for credit scoring must do not infer a control or scheme beyond the transaction and entitlement evidence.