Assess whether HMDA data can be relied on for the exam (5a0c49)

Situation

In an institution preparing for a redlining exam, credit-card limit assignment disparity table is the evidence after a SPCP that originated almost no loans to the intended class. CRA strategist has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending Redlining and HMDA Data close using credit-card limit assignment disparity table.

Decision

CRA strategist in an institution preparing for a redlining exam 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 SPCP that originated almost no loans to the intended class.

Hypotheses to test

• Authorize Remove access or reverse the item on HMDA data can be relied on now if credit-card limit assignment disparity table after a SPCP that originated almost no loans to the intended class already carries the Redlining and HMDA Data discriminator for CRA strategist.
• Keep Temporary compensating control in force until credit-card limit assignment disparity table is completed after a SPCP that originated almost no loans to the intended class in an institution preparing for a redlining exam.
• Treat credit-card limit assignment disparity table as Approve a documented exception because both Remove access or reverse the item and Temporary compensating control appear after a SPCP that originated almost no loans to the intended class.
• CRA strategist does not have the page HMDA data can be relied on turns on in credit-card limit assignment disparity table; refuse a Fair Lending close.

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 SPCP that originated almost no loans to the intended class.
• For this Fair Lending Redlining and HMDA Data file, read credit-card limit assignment disparity table against a SPCP that originated almost no loans to the intended class and write the one fact that would move HMDA data can be relied on for CRA strategist.

Recommendation