Assess whether HMDA data can be relied on for the exam (4c3ac7)

Situation

A SPCP that originated almost no loans to the intended class put SPCP written plan versus actual originations in front of fair-lending officer in a manufactured-housing lender with dealer-originated files. This Fair Lending / Redlining and HMDA Data close is HMDA data can be relied on from SPCP written plan versus actual originations, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

Decision

Fair-lending officer 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 a SPCP that originated almost no loans to the intended class.

Hypotheses to test

• The population in SPCP written plan versus actual originations is the one a SPCP that originated almost no loans to the intended class named, so Remove access or reverse the item follows for this Redlining and HMDA Data file.
• The population in SPCP written plan versus actual originations is adjacent only to a SPCP that originated almost no loans to the intended class; Temporary compensating control is the honest Fair Lending call.
• A manufactured-housing lender with dealer-originated files already contained a SPCP that originated almost no loans to the intended class before SPCP written plan versus actual originations arrived; no new Redlining and HMDA Data path.
• Provenance on SPCP written plan versus actual originations after a SPCP that originated almost no loans to the intended class is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Flag any disparate-impact table fair-lending officer cannot explain from SPCP written plan versus actual originations.
• Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend.
• Match the adverse-action language to the facts in SPCP written plan versus actual originations.
• For this Fair Lending Redlining and HMDA Data file, read SPCP written plan versus actual originations against a SPCP that originated almost no loans to the intended class and write the one fact that would move HMDA data can be relied on for fair-lending officer.