Whether HMDA data can be relied on for the exam from geographic application

Situation

HMDA data-quality manager in a lender expanding into majority-minority census tracts has one working extract — geographic application and origination heat map — after a board asking if the bank should settle a matched-pair study. If geographic application and origination heat map cannot support HMDA data can be relied on, the honest Fair Lending output is hold.

Decision

HMDA data-quality manager in a lender expanding into majority-minority census tracts 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 board asking if the bank should settle a matched-pair study.

Hypotheses to test

• HMDA data-quality manager can defend Remove access or reverse the item from geographic application and origination heat map after a board asking if the bank should settle a matched-pair study in a Fair Lending challenge.
• HMDA data-quality manager cannot defend Remove access or reverse the item from geographic application and origination heat map; Temporary compensating control is what the extract actually supports after a board asking if the bank should settle a matched-pair study.
• A board asking if the bank should settle a matched-pair study never reached the population in geographic application and origination heat map — reopen intake, do not close HMDA data can be relied on.
• Two facts in geographic application and origination heat map after a board asking if the bank should settle a matched-pair study conflict for HMDA data-quality manager; hold this Pricing and Credit Limits file.

Analysis required

• Flag any disparate-impact table HMDA data-quality manager cannot explain from geographic application and origination heat map.
• Test a documented exception versus a pattern a lender expanding into majority-minority census tracts 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 board asking if the bank should settle a matched-pair study and write the one fact that would move HMDA data can be relied on for HMDA data-quality manager.

Recommendation