Assess whether HMDA data can be relied on for the exam (c7afed)

Situation

A community complaint about appraisal gaps put CRA assessment-area versus lending footprint in front of HMDA data-quality manager in a small-business desk using a new vendor score. This Fair Lending / Examination and Notices close is HMDA data can be relied on from CRA assessment-area versus lending footprint, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

Decision

HMDA data-quality manager 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 CRA assessment-area versus lending footprint after a community complaint about appraisal gaps.

Hypotheses to test

• CRA assessment-area versus lending footprint reads as Remove access or reverse the item once a community complaint about appraisal gaps is lined up to the same Fair Lending population.
• CRA assessment-area versus lending footprint is closer to Temporary compensating control after a community complaint about appraisal gaps; Remove access or reverse the item would over-claim this Examination and Notices extract.
• Approve a documented exception is still live in CRA assessment-area versus lending footprint for HMDA data-quality manager in a small-business desk using a new vendor score.
• CRA assessment-area versus lending footprint is missing the fact HMDA data-quality manager needs after a community complaint about appraisal gaps; stop this Fair Lending close.

Analysis required

• Compare CRA assessment-area versus lending footprint to similarly situated files, second-review notes, and reason codes after a community complaint about appraisal gaps.
• Flag any disparate-impact table HMDA data-quality manager cannot explain from CRA assessment-area versus lending footprint.
• Test a documented exception versus a pattern a small-business desk using a new vendor score must defend.
• For this Fair Lending Examination and Notices file, read CRA assessment-area versus lending footprint against a community complaint about appraisal gaps and write the one fact that would move HMDA data can be relied on 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 / Examination and Notices packet (CRA assessment-area versus lending footprint after a community complaint about appraisal gaps). Lead with the Fair Lending option CRA assessment-area versus lending footprint can support after a community complaint about appraisal gaps, then the two facts that force it, then the Monday action for HMDA data-quality manager in a small-business desk using a new vendor score.