Whether a redlining pattern exists after controls from HMDA LAR validity

Situation

The desk packet is HMDA LAR validity and quality edits after a marketing mailer that skipped majority-minority tracts. Community-development lender in a bank with thin HMDA LAR quality has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending Pricing and Credit Limits file.

Decision

Community-development lender 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 HMDA LAR validity and quality edits after a marketing mailer that skipped majority-minority tracts.

Hypotheses to test

• Community-development lender can defend Remove access or reverse the item from HMDA LAR validity and quality edits after a marketing mailer that skipped majority-minority tracts in a Fair Lending challenge.
• Community-development lender cannot defend Remove access or reverse the item from HMDA LAR validity and quality edits; Temporary compensating control is what the extract actually supports after a marketing mailer that skipped majority-minority tracts.
• A marketing mailer that skipped majority-minority tracts never reached the population in HMDA LAR validity and quality edits — reopen intake, do not close a redlining pattern exists.
• Two facts in HMDA LAR validity and quality edits after a marketing mailer that skipped majority-minority tracts conflict for community-development lender; hold this Pricing and Credit Limits file.

Analysis required

• 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 HMDA LAR validity and quality edits.
• Check HMDA coding and underwriting policy against a redlining pattern exists.
• For this Fair Lending Pricing and Credit Limits file, read HMDA LAR validity and quality edits against a marketing mailer that skipped majority-minority tracts and write the one fact that would move a redlining pattern exists for community-development lender.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Pricing and Credit Limits packet (HMDA LAR validity and quality edits after a marketing mailer that skipped majority-minority tracts). The follow-on Pricing and Credit Limits action is what community-development lender does next: implement the option, assign an owner, and log the missing fact.