Adverse-action notice operations lead must resolve whether HMDA data can be

Situation

Pricing and Credit Limits work in a credit union rolling out a special-purpose credit program now turns on HMDA data can be relied on because a branch that stopped taking applications in one ZIP put geographic application and origination heat map in play. Adverse-action notice operations lead should say what geographic application and origination heat map proves.

Decision

Adverse-action notice operations lead in a credit union rolling out a special-purpose credit program 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 branch that stopped taking applications in one ZIP.

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 branch that stopped taking applications in one ZIP 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 branch that stopped taking applications in one ZIP.
• A branch that stopped taking applications in one ZIP 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 branch that stopped taking applications in one ZIP conflict for adverse-action notice operations lead; hold this Pricing and Credit Limits 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 branch that stopped taking applications in one ZIP.
• Flag any disparate-impact table adverse-action notice operations lead cannot explain from geographic application and origination heat map.
• For this Fair Lending Pricing and Credit Limits file, read geographic application and origination heat map against a branch that stopped taking applications in one ZIP and write the one fact that would move HMDA data can be relied on for adverse-action notice operations lead.