Assess whether a redlining pattern exists after controls (7ede86)

Situation

After a HMDA resubmission that still fails quality edits, SPCP written plan versus actual originations is what HMDA data-quality manager can touch in a credit union rolling out a special-purpose credit program. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this CRA and Special-Purpose Programs file.

Decision

HMDA data-quality manager 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 HMDA resubmission that still fails quality edits.

Hypotheses to test

• SPCP written plan versus actual originations reads as Remove access or reverse the item once a HMDA resubmission that still fails quality edits is lined up to the same Fair Lending population.
• SPCP written plan versus actual originations is closer to Temporary compensating control after a HMDA resubmission that still fails quality edits; Remove access or reverse the item would over-claim this CRA and Special-Purpose Programs extract.
• Approve a documented exception is still live in SPCP written plan versus actual originations for HMDA data-quality manager in a credit union rolling out a special-purpose credit program.
• SPCP written plan versus actual originations is missing the fact HMDA data-quality manager needs after a HMDA resubmission that still fails quality edits; stop this Fair Lending close.

Analysis required

• Check HMDA coding and underwriting policy against a redlining pattern exists.
• Compare SPCP written plan versus actual originations to similarly situated files, second-review notes, and reason codes after a HMDA resubmission that still fails quality edits.
• Flag any disparate-impact table HMDA data-quality manager cannot explain from SPCP written plan versus actual originations.
• For this Fair Lending CRA and Special-Purpose Programs 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 a redlining pattern exists for HMDA data-quality manager.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / CRA and Special-Purpose Programs packet (SPCP written plan versus actual originations after a HMDA resubmission that still fails quality edits). The follow-on CRA and Special-Purpose Programs action is what HMDA data-quality manager does next: implement the option, assign an owner, and log the missing fact.