Assess whether notices match the actual decisioning reasons (e0fff1)

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 HMDA resubmission that still fails quality edits put SPCP written plan versus actual originations in play. Model-risk partner for credit scoring should say what SPCP written plan versus actual originations 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 SPCP written plan versus actual originations after a HMDA resubmission that still fails quality edits.

HYPOTHESES TO TEST 1. A HMDA resubmission that still fails quality edits is noise around an already-controlled Redlining and HMDA Data process in a credit union rolling out a special-purpose credit program, given SPCP written plan versus actual originations. 2. A HMDA resubmission that still fails quality edits is the event in SPCP written plan versus actual originations that forces Remove access or reverse the item for model-risk partner for credit scoring under Fair Lending. 3. SPCP written plan versus actual originations shows a one-file miss after a HMDA resubmission that still fails quality edits, not a Redlining and HMDA Data program failure. 4. SPCP written plan versus actual originations cannot decide notices match the actual yet after a HMDA resubmission that still fails quality edits; hold is the only Fair Lending close a credit union rolling out a special-purpose credit program can defend.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in SPCP written plan versus actual originations. 2. Check HMDA coding and underwriting policy against notices match the actual. 3. Compare SPCP written plan versus actual originations to similarly situated files, second-review notes, and reason codes after a HMDA resubmission that still fails quality edits. 4. For this Fair Lending Redlining and HMDA Data file, read SPCP written plan versus actual originations against a HMDA resubmission that still fails quality edits 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 (SPCP written plan versus actual originations after a HMDA resubmission that still fails quality edits). If SPCP written plan versus actual originations cannot force a Fair Lending label under Redlining and HMDA Data, stop. If SPCP written plan versus actual originations after a HMDA resubmission that still fails quality edits 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.