HMDA data-quality manager must resolve whether the exam response should

Situation

A DOJ or CFPB monitor request for pricing files put adverse-action notice principal-reason sample in front of HMDA data-quality manager in a lender expanding into majority-minority census tracts. This Fair Lending / Pricing and Credit Limits close is the exam response should from adverse-action notice principal-reason sample, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

Decision

HMDA data-quality manager in a lender expanding into majority-minority census tracts must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using adverse-action notice principal-reason sample after a DOJ or CFPB monitor request for pricing files.

Hypotheses to test

• Adverse-action notice principal-reason sample reads as Remove access or reverse the item once a DOJ or CFPB monitor request for pricing files is lined up to the same Fair Lending population.
• Adverse-action notice principal-reason sample is closer to Temporary compensating control after a DOJ or CFPB monitor request for pricing files; Remove access or reverse the item would over-claim this Pricing and Credit Limits extract.
• Approve a documented exception is still live in adverse-action notice principal-reason sample for HMDA data-quality manager in a lender expanding into majority-minority census tracts.
• Adverse-action notice principal-reason sample is missing the fact HMDA data-quality manager needs after a DOJ or CFPB monitor request for pricing files; stop this Fair Lending close.

Analysis required

• Check HMDA coding and underwriting policy against the exam response should.
• Compare adverse-action notice principal-reason sample to similarly situated files, second-review notes, and reason codes after a DOJ or CFPB monitor request for pricing files.
• Flag any disparate-impact table HMDA data-quality manager cannot explain from adverse-action notice principal-reason sample.
• For this Fair Lending Pricing and Credit Limits file, read adverse-action notice principal-reason sample against a DOJ or CFPB monitor request for pricing files and write the one fact that would move the exam response should for HMDA data-quality manager.

Recommendation