Assess whether HMDA data can be relied on for the exam (906186)

Situation

Adverse-action notice operations lead owns HMDA data can be relied on inside a lender expanding into majority-minority census tracts with geographic application and origination heat map as the only packet. A CRA PE that called the assessment area too narrow is what changed the clock for this Fair Lending Redlining and HMDA Data file.

Decision

Adverse-action notice operations lead 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 CRA PE that called the assessment area too narrow.

Hypotheses to test

• Adverse-action notice operations lead can defend Remove access or reverse the item from geographic application and origination heat map after a CRA PE that called the assessment area too narrow in a Fair Lending challenge.
• Adverse-action notice operations lead 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 CRA PE that called the assessment area too narrow.
• A CRA PE that called the assessment area too narrow 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 CRA PE that called the assessment area too narrow conflict for adverse-action notice operations lead; hold this Redlining and HMDA Data file.

Analysis required

• Check HMDA coding and underwriting policy against HMDA data can be relied on.
• Compare geographic application and origination heat map to similarly situated files, second-review notes, and reason codes after a CRA PE that called the assessment area too narrow.
• Flag any disparate-impact table adverse-action notice operations lead cannot explain from geographic application and origination heat map.
• For this Fair Lending Redlining and HMDA Data file, read geographic application and origination heat map 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 adverse-action notice operations lead.

Recommendation