Assess whether HMDA data can be relied on for the exam after a branch that

Situation

The Examination and Notices desk packet is SPCP written plan versus actual originations after a branch that stopped taking applications in one ZIP. Second-review underwriter in a credit union rolling out a special-purpose credit program must name Remove access or reverse the item or Temporary compensating control for this Fair Lending file. Second-review underwriter in a credit union rolling out a special-purpose credit program has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending Examination and Notices file.

Decision

Second-review underwriter in a credit union rolling out a special-purpose credit program 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 branch that stopped taking applications in one ZIP.

Hypotheses to test

• A branch that stopped taking applications in one ZIP is noise around an already-controlled Examination and Notices process in a credit union rolling out a special-purpose credit program, given SPCP written plan versus actual originations.
• A branch that stopped taking applications in one ZIP is the event in SPCP written plan versus actual originations that forces Remove access or reverse the item for second-review underwriter under Fair Lending.
• SPCP written plan versus actual originations shows a one-file miss after a branch that stopped taking applications in one ZIP, not a Examination and Notices program failure.
• SPCP written plan versus actual originations cannot decide HMDA data can be relied on yet after a branch that stopped taking applications in one ZIP; hold is the only Fair Lending close a credit union rolling out a special-purpose credit program can defend.

Analysis required

• 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 a branch that stopped taking applications in one ZIP.
• Flag any disparate-impact table second-review underwriter cannot explain from SPCP written plan versus actual originations.
• For this Fair Lending Examination and Notices file, read SPCP written plan versus actual originations 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 second-review underwriter.