Assess whether HMDA data can be relied on for the exam (e3956a)

Situation

HMDA data can be relied on sits with CRA strategist because a board asking if the bank should settle a matched-pair study hit a bank with thin HMDA LAR quality. Evidence is underwriting exception log by branch; 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 underwriting exception log by branch after a board asking if the bank should settle a matched-pair study.

Hypotheses to test

• The population in underwriting exception log by branch is the one a board asking if the bank should settle a matched-pair study named, so Remove access or reverse the item follows for this Examination and Notices file.
• The population in underwriting exception log by branch is adjacent only to a board asking if the bank should settle a matched-pair study; Temporary compensating control is the honest Fair Lending call.
• A bank with thin HMDA LAR quality already contained a board asking if the bank should settle a matched-pair study before underwriting exception log by branch arrived; no new Examination and Notices path.
• Provenance on underwriting exception log by branch after a board asking if the bank should settle a matched-pair study is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Flag any disparate-impact table CRA strategist cannot explain from underwriting exception log by branch.
• 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 underwriting exception log by branch.
• For this Fair Lending Examination and Notices file, read underwriting exception log by branch 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 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 (underwriting exception log by branch after a board asking if the bank should settle a matched-pair study). Lead with the Fair Lending option underwriting exception log by branch can support after a board asking if the bank should settle a matched-pair study, then the two facts that force it, then the Monday action for CRA strategist in a bank with thin HMDA LAR quality.