Assess whether HMDA data can be relied on for the exam (48b6b0)

Situation

In a small-business desk using a new vendor score, appraisal-gap outcomes in majority-minority tracts is the evidence after a community complaint about appraisal gaps. Adverse-action notice operations lead has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending CRA and Special-Purpose Programs close using appraisal-gap outcomes in majority-minority tracts.

Decision

Adverse-action notice operations lead 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 appraisal-gap outcomes in majority-minority tracts after a community complaint about appraisal gaps.

Hypotheses to test

• Adverse-action notice operations lead can defend Remove access or reverse the item from appraisal-gap outcomes in majority-minority tracts after a community complaint about appraisal gaps in a Fair Lending challenge.
• Adverse-action notice operations lead cannot defend Remove access or reverse the item from appraisal-gap outcomes in majority-minority tracts; Temporary compensating control is what the extract actually supports after a community complaint about appraisal gaps.
• A community complaint about appraisal gaps never reached the population in appraisal-gap outcomes in majority-minority tracts — reopen intake, do not close HMDA data can be relied on.
• Two facts in appraisal-gap outcomes in majority-minority tracts after a community complaint about appraisal gaps conflict for adverse-action notice operations lead; hold this CRA and Special-Purpose Programs file.

Analysis required

• Match the adverse-action language to the facts in appraisal-gap outcomes in majority-minority tracts.
• Check HMDA coding and underwriting policy against HMDA data can be relied on.
• Compare appraisal-gap outcomes in majority-minority tracts to similarly situated files, second-review notes, and reason codes after a community complaint about appraisal gaps.
• For this Fair Lending CRA and Special-Purpose Programs file, read appraisal-gap outcomes in majority-minority tracts against a community complaint about appraisal gaps and write the one fact that would move HMDA data can be relied on for adverse-action notice operations lead.

Recommendation