Assess whether HMDA data can be relied on for the exam (19f556)

Situation

The desk packet is credit-card limit assignment disparity table after a branch that stopped taking applications in one ZIP. Exam-response coordinator in a mortgage company after a pricing-regression spike has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending Examination and Notices file.

Decision

Exam-response coordinator in a mortgage company after a pricing-regression spike must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using credit-card limit assignment disparity table after a branch that stopped taking applications in one ZIP.

Hypotheses to test

• The population in credit-card limit assignment disparity table 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 credit-card limit assignment disparity table is adjacent only to a branch that stopped taking applications in one ZIP; Temporary compensating control is the honest Fair Lending call.
• A mortgage company after a pricing-regression spike already contained a branch that stopped taking applications in one ZIP before credit-card limit assignment disparity table arrived; no new Examination and Notices path.
• Provenance on credit-card limit assignment disparity table 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

• Match the adverse-action language to the facts in credit-card limit assignment disparity table.
• Check HMDA coding and underwriting policy against HMDA data can be relied on.
• Compare credit-card limit assignment disparity table to similarly situated files, second-review notes, and reason codes after a branch that stopped taking applications in one ZIP.
• For this Fair Lending Examination and Notices file, read credit-card limit assignment disparity table 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 exam-response coordinator.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Examination and Notices packet (credit-card limit assignment disparity table after a branch that stopped taking applications in one ZIP). If credit-card limit assignment disparity table cannot force a Fair Lending label under Examination and Notices, stop. If credit-card limit assignment disparity table after a branch that stopped taking applications in one ZIP cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending Examination and Notices close, exam-response coordinator must do not infer a control or scheme beyond the transaction and entitlement evidence.