Whether HMDA data can be relied on for the exam from CRA assessment-area

Situation

After a CRA PE that called the assessment area too narrow, CRA assessment-area versus lending footprint is what fair-lending officer can touch in a mortgage company after a pricing-regression spike. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this Pricing and Credit Limits file.

Decision

Fair-lending officer in a mortgage company after a pricing-regression spike 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 CRA PE that called the assessment area too narrow.

Hypotheses to test

• Fair-lending officer can defend Remove access or reverse the item from CRA assessment-area versus lending footprint after a CRA PE that called the assessment area too narrow in a Fair Lending challenge.
• Fair-lending officer cannot defend Remove access or reverse the item from CRA assessment-area versus lending footprint; Temporary compensating control is what the extract actually supports after a CRA PE that called the assessment area too narrow.
• A CRA PE that called the assessment area too narrow never reached the population in CRA assessment-area versus lending footprint — reopen intake, do not close HMDA data can be relied on.
• Two facts in CRA assessment-area versus lending footprint after a CRA PE that called the assessment area too narrow conflict for fair-lending officer; hold this Pricing and Credit Limits file.

Analysis required

• Flag any disparate-impact table fair-lending officer cannot explain from CRA assessment-area versus lending footprint.
• Test a documented exception versus a pattern a mortgage company after a pricing-regression spike must defend.
• Match the adverse-action language to the facts in CRA assessment-area versus lending footprint.
• For this Fair Lending Pricing and Credit Limits file, read CRA assessment-area versus lending footprint against a CRA PE that called the assessment area too narrow and write the one fact that would move HMDA data can be relied on for fair-lending officer.

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 (CRA assessment-area versus lending footprint after a CRA PE that called the assessment area too narrow). Lead with the Fair Lending option CRA assessment-area versus lending footprint can support after a CRA PE that called the assessment area too narrow, then the two facts that force it, then the Monday action for fair-lending officer in a mortgage company after a pricing-regression spike.