Assess whether HMDA data can be relied on for the exam (3c0e77)

Situation

A HMDA resubmission that still fails quality edits put CRA assessment-area versus lending footprint in front of model-risk partner for credit scoring in a credit union rolling out a special-purpose credit program. This Fair Lending / Redlining and HMDA Data close is HMDA data can be relied on from CRA assessment-area versus lending footprint, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

Decision

Model-risk partner for credit scoring 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 CRA assessment-area versus lending footprint after a HMDA resubmission that still fails quality edits.

Hypotheses to test

• The population in CRA assessment-area versus lending footprint is the one a HMDA resubmission that still fails quality edits named, so Remove access or reverse the item follows for this Redlining and HMDA Data file.
• The population in CRA assessment-area versus lending footprint is adjacent only to a HMDA resubmission that still fails quality edits; Temporary compensating control is the honest Fair Lending call.
• A credit union rolling out a special-purpose credit program already contained a HMDA resubmission that still fails quality edits before CRA assessment-area versus lending footprint arrived; no new Redlining and HMDA Data path.
• Provenance on CRA assessment-area versus lending footprint after a HMDA resubmission that still fails quality edits is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• 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.
• Compare CRA assessment-area versus lending footprint to similarly situated files, second-review notes, and reason codes after a HMDA resubmission that still fails quality edits.
• For this Fair Lending Redlining and HMDA Data file, read CRA assessment-area versus lending footprint against a HMDA resubmission that still fails quality edits and write the one fact that would move HMDA data can be relied on for model-risk partner for credit scoring.