Assess whether HMDA data can be relied on for the exam (7d90ab)

Situation

CRA assessment-area versus lending footprint arrived with a branch that stopped taking applications in one ZIP for HMDA data-quality manager. That is a Fair Lending Examination and Notices decision on HMDA data can be relied on in a small-business desk using a new vendor score.

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 branch that stopped taking applications in one ZIP.

Hypotheses to test

• The population in CRA assessment-area versus lending footprint is the one a branch that stopped taking applications in one ZIP named, so Remove access or reverse the item follows for this Examination and Notices file.
• The population in CRA assessment-area versus lending footprint is adjacent only to a branch that stopped taking applications in one ZIP; Temporary compensating control is the honest Fair Lending call.
• A small-business desk using a new vendor score already contained a branch that stopped taking applications in one ZIP before CRA assessment-area versus lending footprint arrived; no new Examination and Notices path.
• Provenance on CRA assessment-area versus lending footprint after a branch that stopped taking applications in one ZIP is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Test a documented exception versus a pattern a small-business desk using a new vendor score must defend.
• Match the adverse-action language to the facts in CRA assessment-area versus lending footprint.
• Check HMDA coding and underwriting policy against HMDA data can be relied on.
• For this Fair Lending Examination and Notices file, read CRA assessment-area versus lending footprint against a branch that stopped taking applications in one ZIP 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 branch that stopped taking applications in one ZIP). Lead with the Fair Lending option CRA assessment-area versus lending footprint can support after a branch that stopped taking applications in one ZIP, 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.