Assess whether HMDA data can be relied on for the exam (fd24bc)

Situation

A marketing mailer that skipped majority-minority tracts put HMDA LAR validity and quality edits in front of CRA strategist in a bank with thin HMDA LAR quality. This Fair Lending / Examination and Notices close is HMDA data can be relied on from HMDA LAR validity and quality edits, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

Decision

CRA strategist in a bank with thin HMDA LAR quality must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using HMDA LAR validity and quality edits after a marketing mailer that skipped majority-minority tracts.

Hypotheses to test

• The population in HMDA LAR validity and quality edits is the one a marketing mailer that skipped majority-minority tracts named, so Remove access or reverse the item follows for this Examination and Notices file.
• The population in HMDA LAR validity and quality edits is adjacent only to a marketing mailer that skipped majority-minority tracts; Temporary compensating control is the honest Fair Lending call.
• A bank with thin HMDA LAR quality already contained a marketing mailer that skipped majority-minority tracts before HMDA LAR validity and quality edits arrived; no new Examination and Notices path.
• Provenance on HMDA LAR validity and quality edits after a marketing mailer that skipped majority-minority tracts is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Match the adverse-action language to the facts in HMDA LAR validity and quality edits.
• Check HMDA coding and underwriting policy against HMDA data can be relied on.
• Compare HMDA LAR validity and quality edits to similarly situated files, second-review notes, and reason codes after a marketing mailer that skipped majority-minority tracts.
• For this Fair Lending Examination and Notices file, read HMDA LAR validity and quality edits against a marketing mailer that skipped majority-minority tracts and write the one fact that would move HMDA data can be relied on for CRA strategist.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Examination and Notices packet (HMDA LAR validity and quality edits after a marketing mailer that skipped majority-minority tracts). Lead with the Fair Lending option HMDA LAR validity and quality edits can support after a marketing mailer that skipped majority-minority tracts, then the two facts that force it, then the Monday action for CRA strategist in a bank with thin HMDA LAR quality.