Assess whether HMDA data can be relied on for the exam (d24eae)

Situation

In a mortgage company after a pricing-regression spike, mortgage pricing residual by prohibited-basis group is the evidence after a board asking if the bank should settle a matched-pair study. CRA strategist has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending CRA and Special-Purpose Programs close using mortgage pricing residual by prohibited-basis group.

Decision

CRA strategist in a mortgage company after a pricing-regression spike 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 a board asking if the bank should settle a matched-pair study.

Hypotheses to test

• A board asking if the bank should settle a matched-pair study is noise around an already-controlled CRA and Special-Purpose Programs process in a mortgage company after a pricing-regression spike, given mortgage pricing residual by prohibited-basis group.
• A board asking if the bank should settle a matched-pair study is the event in mortgage pricing residual by prohibited-basis group that forces Remove access or reverse the item for CRA strategist under Fair Lending.
• Mortgage pricing residual by prohibited-basis group shows a one-file miss after a board asking if the bank should settle a matched-pair study, not a CRA and Special-Purpose Programs program failure.
• Mortgage pricing residual by prohibited-basis group cannot decide HMDA data can be relied on yet after a board asking if the bank should settle a matched-pair study; hold is the only Fair Lending close a mortgage company after a pricing-regression spike can defend.

Analysis required

• Test a documented exception versus a pattern a mortgage company after a pricing-regression spike 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 CRA and Special-Purpose Programs file, read mortgage pricing residual by prohibited-basis group against a board asking if the bank should settle a matched-pair study and write the one fact that would move HMDA data can be relied on for CRA strategist.

Recommendation