Whether a redlining pattern exists after controls from credit-card limit

Situation

Credit-card limit assignment disparity table arrived with a HMDA resubmission that still fails quality edits for second-review underwriter. That is a Fair Lending Redlining and HMDA Data decision on a redlining pattern exists in a small-business desk using a new vendor score.

Decision

Second-review underwriter 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 credit-card limit assignment disparity table after a HMDA resubmission that still fails quality edits.

Hypotheses to test

• The population in credit-card limit assignment disparity table is the one a HMDA resubmission that still fails quality edits named, so Remove access or reverse the item follows for this Redlining and HMDA Data file.
• The population in credit-card limit assignment disparity table is adjacent only to a HMDA resubmission that still fails quality edits; Temporary compensating control is the honest Fair Lending call.
• A small-business desk using a new vendor score already contained a HMDA resubmission that still fails quality edits before credit-card limit assignment disparity table arrived; no new Redlining and HMDA Data path.
• Provenance on credit-card limit assignment disparity table after a HMDA resubmission that still fails quality edits is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Check HMDA coding and underwriting policy against a redlining pattern exists.
• Compare credit-card limit assignment disparity table to similarly situated files, second-review notes, and reason codes after a HMDA resubmission that still fails quality edits.
• Flag any disparate-impact table second-review underwriter cannot explain from credit-card limit assignment disparity table.
• For this Fair Lending Redlining and HMDA Data file, read credit-card limit assignment disparity table against a HMDA resubmission that still fails quality edits and write the one fact that would move a redlining pattern exists for second-review underwriter.

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 (credit-card limit assignment disparity table after a HMDA resubmission that still fails quality edits). The follow-on Redlining and HMDA Data action is what second-review underwriter does next: implement the option, assign an owner, and log the missing fact.