Assess whether HMDA data can be relied on for the exam (4a462c)

Situation

The desk packet is model-reason-code mapping that does not match notices after a DOJ or CFPB monitor request for pricing files. CRA strategist in a bank with thin HMDA LAR quality has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending Examination and Notices file.

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 model-reason-code mapping that does not match notices after a DOJ or CFPB monitor request for pricing files.

Hypotheses to test

• Model-reason-code mapping that does not match notices reads as Remove access or reverse the item once a DOJ or CFPB monitor request for pricing files is lined up to the same Fair Lending population.
• Model-reason-code mapping that does not match notices is closer to Temporary compensating control after a DOJ or CFPB monitor request for pricing files; Remove access or reverse the item would over-claim this Examination and Notices extract.
• Approve a documented exception is still live in model-reason-code mapping that does not match notices for CRA strategist in a bank with thin HMDA LAR quality.
• Model-reason-code mapping that does not match notices is missing the fact CRA strategist needs after a DOJ or CFPB monitor request for pricing files; stop this Fair Lending close.

Analysis required

• Compare model-reason-code mapping that does not match notices to similarly situated files, second-review notes, and reason codes after a DOJ or CFPB monitor request for pricing files.
• Flag any disparate-impact table CRA strategist cannot explain from model-reason-code mapping that does not match notices.
• Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend.
• For this Fair Lending Examination and Notices file, read model-reason-code mapping that does not match notices against a DOJ or CFPB monitor request for pricing files 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 (model-reason-code mapping that does not match notices after a DOJ or CFPB monitor request for pricing files). The follow-on Examination and Notices action is what CRA strategist does next: implement the option, assign an owner, and log the missing fact.