Assess whether HMDA data can be relied on for the exam (d8a895)

Situation

A manufactured-housing lender with dealer-originated files cannot treat a board asking if the bank should settle a matched-pair study as color commentary on credit-card limit assignment disparity table. CRA strategist must close HMDA data can be relied on from that extract under Fair Lending / Pricing and Credit Limits.

Decision

CRA strategist in a manufactured-housing lender with dealer-originated files 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 board asking if the bank should settle a matched-pair study.

Hypotheses to test

• Authorize Remove access or reverse the item now; credit-card limit assignment disparity table already has the discriminator after a board asking if the bank should settle a matched-pair study.
• Keep Temporary compensating control in force until credit-card limit assignment disparity table is completed after a board asking if the bank should settle a matched-pair study for CRA strategist.
• Treat credit-card limit assignment disparity table as Approve a documented exception because both readings appear after a board asking if the bank should settle a matched-pair study.
• Refuse a Fair Lending close: CRA strategist does not have the page HMDA data can be relied on turns on in credit-card limit assignment disparity table.

Analysis required

• Match the adverse-action language to the facts in credit-card limit assignment disparity table.
• 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 board asking if the bank should settle a matched-pair study.
• For this Fair Lending Pricing and Credit Limits file, read credit-card limit assignment disparity table against a board asking if the bank should settle a matched-pair study and write the one fact that would move HMDA data can be relied on for CRA strategist.

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 (credit-card limit assignment disparity table after a board asking if the bank should settle a matched-pair study). If credit-card limit assignment disparity table cannot force a Fair Lending label under Pricing and Credit Limits, stop. If credit-card limit assignment disparity table after a board asking if the bank should settle a matched-pair study cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending Pricing and Credit Limits close, CRA strategist must do not infer a control or scheme beyond the transaction and entitlement evidence.