Assess whether notices match the actual decisioning reasons (afe2c3)

SITUATION Small-business decline comparative file set arrived with a notice that cites 'other' as the principal reason 40% of the time for HMDA data-quality manager. That is a Fair Lending Examination and Notices decision on notices match the actual in a small-business desk using a new vendor score.

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 small-business decline comparative file set after a notice that cites 'other' as the principal reason 40% of the time.

HYPOTHESES TO TEST 1. The population in small-business decline comparative file set 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 Examination and Notices file. 2. The population in small-business decline comparative file set 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 small-business desk using a new vendor score already contained a notice that cites 'other' as the principal reason 40% of the time before small-business decline comparative file set arrived; no new Examination and Notices path. 4. Provenance on small-business decline comparative file set 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. Compare small-business decline comparative file set to similarly situated files, second-review notes, and reason codes after a notice that cites 'other' as the principal reason 40% of the time. 2. Flag any disparate-impact table HMDA data-quality manager cannot explain from small-business decline comparative file set. 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 small-business decline comparative file set 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 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 (small-business decline comparative file set after a notice that cites 'other' as the principal reason 40% of the time). Lead with the Fair Lending option small-business decline comparative file set can support after a notice that cites 'other' as the principal reason 40% of the time, then the two facts that force it, then the Monday action for HMDA data-quality manager in a small-business desk using a new vendor score.