Assess whether HMDA data can be relied on for the exam (60d347)

Situation

Credit-card limit assignment disparity table arrived with a CRA PE that called the assessment area too narrow for fair-lending officer. That is a Fair Lending CRA and Special-Purpose Programs decision on HMDA data can be relied on in a bank with thin HMDA LAR quality.

Decision

Fair-lending officer in a bank with thin HMDA LAR quality 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 CRA PE that called the assessment area too narrow.

Hypotheses to test

• The population in credit-card limit assignment disparity table is the one a CRA PE that called the assessment area too narrow named, so Remove access or reverse the item follows for this CRA and Special-Purpose Programs file.
• The population in credit-card limit assignment disparity table is adjacent only to a CRA PE that called the assessment area too narrow; Temporary compensating control is the honest Fair Lending call.
• A bank with thin HMDA LAR quality already contained a CRA PE that called the assessment area too narrow before credit-card limit assignment disparity table arrived; no new CRA and Special-Purpose Programs path.
• Provenance on credit-card limit assignment disparity table after a CRA PE that called the assessment area too narrow 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 bank with thin HMDA LAR quality must defend.
• 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.
• For this Fair Lending CRA and Special-Purpose Programs file, read credit-card limit assignment disparity table against a CRA PE that called the assessment area too narrow and write the one fact that would move HMDA data can be relied on for fair-lending officer.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / CRA and Special-Purpose Programs packet (credit-card limit assignment disparity table after a CRA PE that called the assessment area too narrow). Lead with the Fair Lending option credit-card limit assignment disparity table can support after a CRA PE that called the assessment area too narrow, then the two facts that force it, then the Monday action for fair-lending officer in a bank with thin HMDA LAR quality.