Assess whether notices match the actual decisioning reasons (b85305)

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 SPCP that originated almost no loans to the intended class 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 SPCP that originated almost no loans to the intended class.

HYPOTHESES TO TEST 1. The population in HMDA LAR validity and quality edits is the one a SPCP that originated almost no loans to the intended class 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 SPCP that originated almost no loans to the intended class; Temporary compensating control is the honest Fair Lending call. 3. A credit union rolling out a special-purpose credit program already contained a SPCP that originated almost no loans to the intended class 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 SPCP that originated almost no loans to the intended class 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 SPCP that originated almost no loans to the intended class 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 SPCP that originated almost no loans to the intended class). Lead with the Fair Lending option HMDA LAR validity and quality edits can support after a SPCP that originated almost no loans to the intended class, then the two facts that force it, then the Monday action for model-risk partner for credit scoring in a credit union rolling out a special-purpose credit program.