Assess whether HMDA data can be relied on for the exam (1f4ab6)

Situation

HMDA data can be relied on sits with HMDA data-quality manager because a marketing mailer that skipped majority-minority tracts hit a small-business desk using a new vendor score. Evidence is CRA assessment-area versus lending footprint; write the Fair Lending Examination and Notices option that extract can carry.

Decision

HMDA data-quality manager in a small-business desk using a new vendor score must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using CRA assessment-area versus lending footprint after a marketing mailer that skipped majority-minority tracts.

Hypotheses to test

• The population in CRA assessment-area versus lending footprint is the one a marketing mailer that skipped majority-minority tracts named, so Remove access or reverse the item follows for this Examination and Notices file.
• The population in CRA assessment-area versus lending footprint is adjacent only to a marketing mailer that skipped majority-minority tracts; Temporary compensating control is the honest Fair Lending call.
• A small-business desk using a new vendor score already contained a marketing mailer that skipped majority-minority tracts before CRA assessment-area versus lending footprint arrived; no new Examination and Notices path.
• Provenance on CRA assessment-area versus lending footprint after a marketing mailer that skipped majority-minority tracts is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Test a documented exception versus a pattern a small-business desk using a new vendor score must defend.
• Match the adverse-action language to the facts in CRA assessment-area versus lending footprint.
• Check HMDA coding and underwriting policy against HMDA data can be relied on.
• For this Fair Lending Examination and Notices file, read CRA assessment-area versus lending footprint against a marketing mailer that skipped majority-minority tracts and write the one fact that would move HMDA data can be relied on 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 / Examination and Notices packet (CRA assessment-area versus lending footprint after a marketing mailer that skipped majority-minority tracts). If CRA assessment-area versus lending footprint cannot force a Fair Lending label under Examination and Notices, stop. If CRA assessment-area versus lending footprint after a marketing mailer that skipped majority-minority tracts cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending Examination and Notices close, HMDA data-quality manager must do not infer a control or scheme beyond the transaction and entitlement evidence.