Assess whether HMDA data can be relied on for the exam (b88e56)

Situation

After a community complaint about appraisal gaps, credit-card limit assignment disparity table is what community-development lender 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 Redlining and HMDA Data file.

Decision

Community-development lender 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 credit-card limit assignment disparity table after a community complaint about appraisal gaps.

Hypotheses to test

• Authorize Remove access or reverse the item now; credit-card limit assignment disparity table already has the discriminator after a community complaint about appraisal gaps.
• Keep Temporary compensating control in force until credit-card limit assignment disparity table is completed after a community complaint about appraisal gaps for community-development lender.
• Treat credit-card limit assignment disparity table as Approve a documented exception because both readings appear after a community complaint about appraisal gaps.
• Refuse a Fair Lending close: community-development lender does not have the page HMDA data can be relied on turns on in credit-card limit assignment disparity table.

Analysis required

• Check HMDA coding and underwriting policy against HMDA data can be relied on.
• Compare credit-card limit assignment disparity table to similarly situated files, second-review notes, and reason codes after a community complaint about appraisal gaps.
• Flag any disparate-impact table community-development lender cannot explain from credit-card limit assignment disparity table.
• For this Fair Lending Redlining and HMDA Data file, read credit-card limit assignment disparity table against a community complaint about appraisal gaps and write the one fact that would move HMDA data can be relied on for community-development lender.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Redlining and HMDA Data packet (credit-card limit assignment disparity table after a community complaint about appraisal gaps). Lead with the Fair Lending option credit-card limit assignment disparity table can support after a community complaint about appraisal gaps, then the two facts that force it, then the Monday action for community-development lender in a mortgage company after a pricing-regression spike.