Assess whether HMDA data can be relied on for the exam (81567a)

Situation

SPCP written plan versus actual originations arrived with an exception rate twice as high for one group after credit controls for exam-response coordinator. That is a Fair Lending CRA and Special-Purpose Programs decision on HMDA data can be relied on in a manufactured-housing lender with dealer-originated files.

Decision

Exam-response coordinator 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 SPCP written plan versus actual originations after an exception rate twice as high for one group after credit controls.

Hypotheses to test

• Authorize Remove access or reverse the item now; SPCP written plan versus actual originations already has the discriminator after an exception rate twice as high for one group after credit controls.
• Keep Temporary compensating control in force until SPCP written plan versus actual originations is completed after an exception rate twice as high for one group after credit controls for exam-response coordinator.
• Treat SPCP written plan versus actual originations as Approve a documented exception because both readings appear after an exception rate twice as high for one group after credit controls.
• Refuse a Fair Lending close: exam-response coordinator does not have the page HMDA data can be relied on turns on in SPCP written plan versus actual originations.

Analysis required

• Match the adverse-action language to the facts in SPCP written plan versus actual originations.
• Check HMDA coding and underwriting policy against HMDA data can be relied on.
• Compare SPCP written plan versus actual originations to similarly situated files, second-review notes, and reason codes after an exception rate twice as high for one group after credit controls.
• For this Fair Lending CRA and Special-Purpose Programs file, read SPCP written plan versus actual originations 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

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / CRA and Special-Purpose Programs packet (SPCP written plan versus actual originations after an exception rate twice as high for one group after credit controls). The follow-on CRA and Special-Purpose Programs action is what exam-response coordinator does next: implement the option, assign an owner, and log the missing fact.