Assess whether notices match the actual decisioning reasons from underwriting

SITUATION HMDA data-quality manager in a lender expanding into majority-minority census tracts has one working extract — underwriting exception log by branch — after a board asking if the bank should settle a matched-pair study. If underwriting exception log by branch cannot support notices match the actual, the only defensible Fair Lending output is hold.

DECISION HMDA data-quality manager in a lender expanding into majority-minority census tracts must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using underwriting exception log by branch after a board asking if the bank should settle a matched-pair study.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; underwriting exception log by branch already has the discriminator after a board asking if the bank should settle a matched-pair study. 2. Keep Temporary compensating control in force until underwriting exception log by branch is completed after a board asking if the bank should settle a matched-pair study for HMDA data-quality manager. 3. Treat underwriting exception log by branch as Approve a documented exception because both readings appear after a board asking if the bank should settle a matched-pair study. 4. Refuse a Fair Lending close: HMDA data-quality manager does not have the decision notices match the actual turns on in underwriting exception log by branch.

ANALYSIS REQUIRED 1. Compare underwriting exception log by branch to similarly situated files, second-review notes, and reason codes after a board asking if the bank should settle a matched-pair study. 2. Flag any disparate-impact table HMDA data-quality manager cannot explain from underwriting exception log by branch. 3. Test a documented exception versus a pattern a lender expanding into majority-minority census tracts must defend. 4. For this Fair Lending Pricing and Credit Limits file, read underwriting exception log by branch against a board asking if the bank should settle a matched-pair study 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 / Pricing and Credit Limits packet (underwriting exception log by branch after a board asking if the bank should settle a matched-pair study). Lead with the Fair Lending option underwriting exception log by branch can support after a board asking if the bank should settle a matched-pair study, then the two facts that force it, then the Monday action for HMDA data-quality manager in a lender expanding into majority-minority census tracts.