Assess whether HMDA data can be relied on for the exam (c1df45)

Situation

HMDA data can be relied on sits with CRA strategist because a HMDA resubmission that still fails quality edits hit a bank with thin HMDA LAR quality. Evidence is SPCP written plan versus actual originations; write the Fair Lending Examination and Notices option that extract can carry.

Decision

CRA strategist in a bank with thin HMDA LAR quality 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 HMDA resubmission that still fails quality edits.

Hypotheses to test

• A HMDA resubmission that still fails quality edits is noise around an already-controlled Examination and Notices process in a bank with thin HMDA LAR quality, given SPCP written plan versus actual originations.
• A HMDA resubmission that still fails quality edits is the event in SPCP written plan versus actual originations that forces Remove access or reverse the item for CRA strategist under Fair Lending.
• SPCP written plan versus actual originations shows a one-file miss after a HMDA resubmission that still fails quality edits, not a Examination and Notices program failure.
• SPCP written plan versus actual originations cannot decide HMDA data can be relied on yet after a HMDA resubmission that still fails quality edits; hold is the only Fair Lending close a bank with thin HMDA LAR quality can defend.

Analysis required

• Flag any disparate-impact table CRA strategist cannot explain from SPCP written plan versus actual originations.
• Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend.
• Match the adverse-action language to the facts in SPCP written plan versus actual originations.
• For this Fair Lending Examination and Notices file, read SPCP written plan versus actual originations against a HMDA resubmission that still fails quality edits 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 / Examination and Notices packet (SPCP written plan versus actual originations after a HMDA resubmission that still fails quality edits). Lead with the Fair Lending option SPCP written plan versus actual originations can support after a HMDA resubmission that still fails quality edits, then the two facts that force it, then the Monday action for CRA strategist in a bank with thin HMDA LAR quality.