Assess whether HMDA data can be relied on for the exam (c3d797)

Situation

A marketing mailer that skipped majority-minority tracts put mortgage pricing residual by prohibited-basis group in front of CRA strategist in a mortgage company after a pricing-regression spike. This Fair Lending / CRA and Special-Purpose Programs close is HMDA data can be relied on from mortgage pricing residual by prohibited-basis group, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

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 marketing mailer that skipped majority-minority tracts.

Hypotheses to test

• Mortgage pricing residual by prohibited-basis group reads as Remove access or reverse the item once a marketing mailer that skipped majority-minority tracts is lined up to the same Fair Lending population.
• Mortgage pricing residual by prohibited-basis group is closer to Temporary compensating control after a marketing mailer that skipped majority-minority tracts; Remove access or reverse the item would over-claim this CRA and Special-Purpose Programs extract.
• Approve a documented exception is still live in mortgage pricing residual by prohibited-basis group for CRA strategist in a mortgage company after a pricing-regression spike.
• Mortgage pricing residual by prohibited-basis group is missing the fact CRA strategist needs after a marketing mailer that skipped majority-minority tracts; stop this Fair Lending close.

Analysis required

• Check HMDA coding and underwriting policy against HMDA data can be relied on.
• Compare mortgage pricing residual by prohibited-basis group to similarly situated files, second-review notes, and reason codes after a marketing mailer that skipped majority-minority tracts.
• Flag any disparate-impact table CRA strategist cannot explain from mortgage pricing residual by prohibited-basis group.
• For this Fair Lending CRA and Special-Purpose Programs file, read mortgage pricing residual by prohibited-basis group 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.