Assess whether HMDA data can be relied on for the exam (860312)

Situation

The desk packet is appraisal-gap outcomes in majority-minority tracts after a DOJ or CFPB monitor request for pricing files. Adverse-action notice operations lead in a credit-card issuer changing line-assignment logic has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending Examination and Notices file.

Decision

Adverse-action notice operations lead in a credit-card issuer changing line-assignment logic 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 DOJ or CFPB monitor request for pricing files.

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 DOJ or CFPB monitor request for pricing files 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 DOJ or CFPB monitor request for pricing files.
• A DOJ or CFPB monitor request for pricing files 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 DOJ or CFPB monitor request for pricing files conflict for adverse-action notice operations lead; hold this Examination and Notices 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 DOJ or CFPB monitor request for pricing files.
• For this Fair Lending Examination and Notices file, read appraisal-gap outcomes in majority-minority tracts against a DOJ or CFPB monitor request for pricing files and write the one fact that would move HMDA data can be relied on for adverse-action notice operations lead.

Recommendation