Assess whether HMDA data can be relied on for the exam (922ab4)

Situation

Community-development lender owns HMDA data can be relied on inside a manufactured-housing lender with dealer-originated files with small-business decline comparative file set as the only packet. A branch that stopped taking applications in one ZIP is what changed the clock for this Fair Lending Examination and Notices file.

Decision

Community-development lender in a manufactured-housing lender with dealer-originated files must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using small-business decline comparative file set 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 small-business decline comparative file set 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 small-business decline comparative file set; 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 small-business decline comparative file set — reopen intake, do not close HMDA data can be relied on.
• Two facts in small-business decline comparative file set after a branch that stopped taking applications in one ZIP conflict for community-development lender; hold this Examination and Notices file.

Analysis required

• Match the adverse-action language to the facts in small-business decline comparative file set.
• Check HMDA coding and underwriting policy against HMDA data can be relied on.
• Compare small-business decline comparative file set to similarly situated files, second-review notes, and reason codes after a branch that stopped taking applications in one ZIP.
• For this Fair Lending Examination and Notices file, read small-business decline comparative file set 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

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Examination and Notices packet (small-business decline comparative file set after a branch that stopped taking applications in one ZIP). If small-business decline comparative file set cannot force a Fair Lending label under Examination and Notices, stop. Do not invent pages a manufactured-housing lender with dealer-originated files does not have.