Assess whether HMDA data can be relied on for the exam (aef69e)

Situation

Community-development lender in an institution preparing for a redlining exam has one working extract — manufactured-housing dealer overlay notes — after a branch that stopped taking applications in one ZIP. If manufactured-housing dealer overlay notes cannot support HMDA data can be relied on, the honest Fair Lending output is hold.

Decision

Community-development lender in an institution preparing for a redlining exam must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using manufactured-housing dealer overlay notes after a branch that stopped taking applications in one ZIP.

Hypotheses to test

• Community-development lender can defend Remove access or reverse the item from manufactured-housing dealer overlay notes after a branch that stopped taking applications in one ZIP in a Fair Lending challenge.
• Community-development lender cannot defend Remove access or reverse the item from manufactured-housing dealer overlay notes; 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 manufactured-housing dealer overlay notes — reopen intake, do not close HMDA data can be relied on.
• Two facts in manufactured-housing dealer overlay notes after a branch that stopped taking applications in one ZIP conflict for community-development lender; hold this CRA and Special-Purpose Programs file.

Analysis required

• Compare manufactured-housing dealer overlay notes 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 community-development lender cannot explain from manufactured-housing dealer overlay notes.
• Test a documented exception versus a pattern an institution preparing for a redlining exam must defend.
• For this Fair Lending CRA and Special-Purpose Programs file, read manufactured-housing dealer overlay notes 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 community-development lender.

Recommendation