Assess whether HMDA data can be relied on for the exam after an exception

Situation

The desk packet is mortgage pricing residual by prohibited-basis group after an exception rate twice as high for one group after credit controls. Exam-response coordinator in an institution preparing for a redlining exam has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending Pricing and Credit Limits file.

Decision

Exam-response coordinator 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 mortgage pricing residual by prohibited-basis group after an exception rate twice as high for one group after credit controls.

Hypotheses to test

• Exam-response coordinator can defend Remove access or reverse the item from mortgage pricing residual by prohibited-basis group after an exception rate twice as high for one group after credit controls in a Fair Lending challenge.
• Exam-response coordinator cannot defend Remove access or reverse the item from mortgage pricing residual by prohibited-basis group; Temporary compensating control is what the extract actually supports after an exception rate twice as high for one group after credit controls.
• An exception rate twice as high for one group after credit controls never reached the population in mortgage pricing residual by prohibited-basis group — reopen intake, do not close HMDA data can be relied on.
• Two facts in mortgage pricing residual by prohibited-basis group after an exception rate twice as high for one group after credit controls conflict for exam-response coordinator; hold this Pricing and Credit Limits file.

Analysis required

• Test a documented exception versus a pattern an institution preparing for a redlining exam must defend.
• Match the adverse-action language to the facts in mortgage pricing residual by prohibited-basis group.
• Check HMDA coding and underwriting policy against HMDA data can be relied on.
• For this Fair Lending Pricing and Credit Limits file, read mortgage pricing residual by prohibited-basis group against an exception rate twice as high for one group after credit controls and write the one fact that would move HMDA data can be relied on for exam-response coordinator.

Recommendation