Assess whether HMDA data can be relied on for the exam (b4a25f)

Situation

A DOJ or CFPB monitor request for pricing files put small-business decline comparative file set in front of CRA strategist in an institution preparing for a redlining exam. This Fair Lending / Redlining and HMDA Data close is HMDA data can be relied on from small-business decline comparative file set, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

Decision

CRA strategist 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 small-business decline comparative file set after a DOJ or CFPB monitor request for pricing files.

Hypotheses to test

• Small-business decline comparative file set 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.
• Small-business decline comparative file set 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 Redlining and HMDA Data extract.
• Approve a documented exception is still live in small-business decline comparative file set for CRA strategist in an institution preparing for a redlining exam.
• Small-business decline comparative file set is missing the fact CRA strategist needs after a DOJ or CFPB monitor request for pricing files; stop this Fair Lending close.

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 DOJ or CFPB monitor request for pricing files.
• For this Fair Lending Redlining and HMDA Data file, read small-business decline comparative file set 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 / Redlining and HMDA Data packet (small-business decline comparative file set after a DOJ or CFPB monitor request for pricing files). Lead with the Fair Lending option small-business decline comparative file set can support after a DOJ or CFPB monitor request for pricing files, then the two facts that force it, then the Monday action for CRA strategist in an institution preparing for a redlining exam.