Assess whether HMDA data can be relied on for the exam (4de9ca)

Situation

Credit-card limit assignment disparity table arrived with an exception rate twice as high for one group after credit controls for exam-response coordinator. That is a Fair Lending CRA and Special-Purpose Programs decision on HMDA data can be relied on in a manufactured-housing lender with dealer-originated files.

Decision

Exam-response coordinator 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 an exception rate twice as high for one group after credit controls.

Hypotheses to test

• Authorize Remove access or reverse the item now; credit-card limit assignment disparity table already has the discriminator after an exception rate twice as high for one group after credit controls.
• Keep Temporary compensating control in force until credit-card limit assignment disparity table is completed after an exception rate twice as high for one group after credit controls for exam-response coordinator.
• Treat credit-card limit assignment disparity table as Approve a documented exception because both readings appear after an exception rate twice as high for one group after credit controls.
• Refuse a Fair Lending close: exam-response coordinator does not have the page HMDA data can be relied on turns on in credit-card limit assignment disparity table.

Analysis required

• Flag any disparate-impact table exam-response coordinator cannot explain from credit-card limit assignment disparity table.
• Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend.
• Match the adverse-action language to the facts in credit-card limit assignment disparity table.
• For this Fair Lending CRA and Special-Purpose Programs file, read credit-card limit assignment disparity table against an exception rate twice as high for one group after credit controls and write the one fact that would move HMDA data can be relied on for exam-response coordinator.

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 an exception rate twice as high for one group after credit controls). Lead with the Fair Lending option credit-card limit assignment disparity table can support after an exception rate twice as high for one group after credit controls, then the two facts that force it, then the Monday action for exam-response coordinator in a manufactured-housing lender with dealer-originated files.