Assess whether HMDA data can be relied on for the exam (4e0ef5)

Situation

Examination and Notices work in a small-business desk using a new vendor score now turns on HMDA data can be relied on because an underwriter chat that used coded language put geographic application and origination heat map in play. Examination and Notices work in a small-business desk using a new vendor score now turns on HMDA data can be relied on because an underwriter chat that used coded language put geographic application and origination heat map in play; HMDA data-quality manager should say what geographic application and origination heat map proves for Fair Lending.

Decision

HMDA data-quality manager in a small-business desk using a new vendor score must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using geographic application and origination heat map after an underwriter chat that used coded language.

Hypotheses to test

• An underwriter chat that used coded language is noise around an already-controlled Examination and Notices process in a small-business desk using a new vendor score, given geographic application and origination heat map.
• An underwriter chat that used coded language is the event in geographic application and origination heat map that forces Remove access or reverse the item for HMDA data-quality manager under Fair Lending.
• Geographic application and origination heat map shows a one-file miss after an underwriter chat that used coded language, not a Examination and Notices program failure.
• Geographic application and origination heat map cannot decide HMDA data can be relied on yet after an underwriter chat that used coded language; hold is the only Fair Lending close a small-business desk using a new vendor score can defend.

Analysis required

• Test a documented exception versus a pattern a small-business desk using a new vendor score must defend.
• Match the adverse-action language to the facts in geographic application and origination heat map.
• Check HMDA coding and underwriting policy against HMDA data can be relied on.
• For this Fair Lending Examination and Notices file, read geographic application and origination heat map against an underwriter chat that used coded language and write the one fact that would move HMDA data can be relied on for HMDA data-quality manager.