Assess whether HMDA data can be relied on for the exam from geographic

Situation

The desk packet is geographic application and origination heat map after a community complaint about appraisal gaps. Fair-lending officer 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 Pricing and Credit Limits file.

Decision

Fair-lending officer 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 geographic application and origination heat map after a community complaint about appraisal gaps.

Hypotheses to test

• The population in geographic application and origination heat map is the one a community complaint about appraisal gaps named, so Remove access or reverse the item follows for this Pricing and Credit Limits file.
• The population in geographic application and origination heat map is adjacent only to a community complaint about appraisal gaps; Temporary compensating control is the honest Fair Lending call.
• A mortgage company after a pricing-regression spike already contained a community complaint about appraisal gaps before geographic application and origination heat map arrived; no new Pricing and Credit Limits path.
• Provenance on geographic application and origination heat map after a community complaint about appraisal gaps is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Flag any disparate-impact table fair-lending officer cannot explain from geographic application and origination heat map.
• Test a documented exception versus a pattern a mortgage company after a pricing-regression spike must defend.
• Match the adverse-action language to the facts in geographic application and origination heat map.
• For this Fair Lending Pricing and Credit Limits file, read geographic application and origination heat map against a community complaint about appraisal gaps 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 / Pricing and Credit Limits packet (geographic application and origination heat map after a community complaint about appraisal gaps). If geographic application and origination heat map cannot force a Fair Lending label under Pricing and Credit Limits, stop. Do not invent pages a mortgage company after a pricing-regression spike does not have.