Community-development lender must resolve whether HMDA data can be relied on

Situation

Community-development lender in a mortgage company after a pricing-regression spike has one working extract — SPCP written plan versus actual originations — after a board asking if the bank should settle a matched-pair study. If SPCP written plan versus actual originations cannot support HMDA data can be relied on, the honest Fair Lending output is hold.

Decision

Community-development lender 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 SPCP written plan versus actual originations after a board asking if the bank should settle a matched-pair study.

Hypotheses to test

• SPCP written plan versus actual originations reads as Remove access or reverse the item once a board asking if the bank should settle a matched-pair study is lined up to the same Fair Lending population.
• SPCP written plan versus actual originations is closer to Temporary compensating control after a board asking if the bank should settle a matched-pair study; Remove access or reverse the item would over-claim this Redlining and HMDA Data extract.
• Approve a documented exception is still live in SPCP written plan versus actual originations for community-development lender in a mortgage company after a pricing-regression spike.
• SPCP written plan versus actual originations is missing the fact community-development lender needs after a board asking if the bank should settle a matched-pair study; stop this Fair Lending close.

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 SPCP written plan versus actual originations.
• Check HMDA coding and underwriting policy against HMDA data can be relied on.
• For this Fair Lending Redlining and HMDA Data file, read SPCP written plan versus actual originations 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 community-development lender.

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 (SPCP written plan versus actual originations after a board asking if the bank should settle a matched-pair study). If SPCP written plan versus actual originations cannot force a Fair Lending label under Redlining and HMDA Data, stop. If SPCP written plan versus actual originations after a board asking if the bank should settle a matched-pair study cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending Redlining and HMDA Data close, community-development lender must do not infer a control or scheme beyond the transaction and entitlement evidence.