Assess whether HMDA data can be relied on for the exam (469de8)

Situation

In a manufactured-housing lender with dealer-originated files, CRA assessment-area versus lending footprint is the evidence after a board asking if the bank should settle a matched-pair study. Exam-response coordinator has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending CRA and Special-Purpose Programs close using CRA assessment-area versus lending footprint.

Decision

Exam-response coordinator in a manufactured-housing lender with dealer-originated files 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 board asking if the bank should settle a matched-pair study.

Hypotheses to test

• Exam-response coordinator can defend Remove access or reverse the item from CRA assessment-area versus lending footprint after a board asking if the bank should settle a matched-pair study in a Fair Lending challenge.
• Exam-response coordinator cannot defend Remove access or reverse the item from CRA assessment-area versus lending footprint; Temporary compensating control is what the extract actually supports after a board asking if the bank should settle a matched-pair study.
• A board asking if the bank should settle a matched-pair study never reached the population in CRA assessment-area versus lending footprint — reopen intake, do not close HMDA data can be relied on.
• Two facts in CRA assessment-area versus lending footprint after a board asking if the bank should settle a matched-pair study conflict for exam-response coordinator; hold this CRA and Special-Purpose Programs file.

Analysis required

• Flag any disparate-impact table exam-response coordinator cannot explain from CRA assessment-area versus lending footprint.
• Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend.
• Match the adverse-action language to the facts in CRA assessment-area versus lending footprint.
• For this Fair Lending CRA and Special-Purpose Programs file, read CRA assessment-area versus lending footprint against a board asking if the bank should settle a matched-pair study and write the one fact that would move HMDA data can be relied on for exam-response coordinator.

Recommendation