Assess whether HMDA data can be relied on for the exam (5f1005)

Situation

Fair-lending officer owns HMDA data can be relied on inside a bank with thin HMDA LAR quality with credit-card limit assignment disparity table as the only packet. A HMDA resubmission that still fails quality edits is what changed the clock for this Fair Lending CRA and Special-Purpose Programs file.

Decision

Fair-lending officer in a bank with thin HMDA LAR quality 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 HMDA resubmission that still fails quality edits.

Hypotheses to test

• Fair-lending officer can defend Remove access or reverse the item from credit-card limit assignment disparity table after a HMDA resubmission that still fails quality edits in a Fair Lending challenge.
• Fair-lending officer cannot defend Remove access or reverse the item from credit-card limit assignment disparity table; Temporary compensating control is what the extract actually supports after a HMDA resubmission that still fails quality edits.
• A HMDA resubmission that still fails quality edits never reached the population in credit-card limit assignment disparity table — reopen intake, do not close HMDA data can be relied on.
• Two facts in credit-card limit assignment disparity table after a HMDA resubmission that still fails quality edits conflict for fair-lending officer; hold this CRA and Special-Purpose Programs file.

Analysis required

• Compare credit-card limit assignment disparity table to similarly situated files, second-review notes, and reason codes after a HMDA resubmission that still fails quality edits.
• Flag any disparate-impact table fair-lending officer cannot explain from credit-card limit assignment disparity table.
• Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend.
• For this Fair Lending CRA and Special-Purpose Programs file, read credit-card limit assignment disparity table against a HMDA resubmission that still fails quality edits 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 / CRA and Special-Purpose Programs packet (credit-card limit assignment disparity table after a HMDA resubmission that still fails quality edits). If credit-card limit assignment disparity table cannot force a Fair Lending label under CRA and Special-Purpose Programs, stop. If credit-card limit assignment disparity table after a HMDA resubmission that still fails quality edits cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending CRA and Special-Purpose Programs close, fair-lending officer must do not infer a control or scheme beyond the transaction and entitlement evidence.