Assess whether HMDA data can be relied on for the exam after a marketing

Situation

A mortgage company after a pricing-regression spike cannot treat a marketing mailer that skipped majority-minority tracts as color commentary on geographic application and origination heat map. Community-development lender must close HMDA data can be relied on from that extract under Fair Lending / Redlining and HMDA Data.

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 geographic application and origination heat map after a marketing mailer that skipped majority-minority tracts.

Hypotheses to test

• The population in geographic application and origination heat map is the one a marketing mailer that skipped majority-minority tracts named, so Remove access or reverse the item follows for this Redlining and HMDA Data file.
• The population in geographic application and origination heat map is adjacent only to a marketing mailer that skipped majority-minority tracts; Temporary compensating control is the honest Fair Lending call.
• A mortgage company after a pricing-regression spike already contained a marketing mailer that skipped majority-minority tracts before geographic application and origination heat map arrived; no new Redlining and HMDA Data path.
• Provenance on geographic application and origination heat map after a marketing mailer that skipped majority-minority tracts is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Test a documented exception versus a pattern a mortgage company after a pricing-regression spike must defend.
• Match the adverse-action language to the facts in geographic application and origination heat map.
• Check HMDA coding and underwriting policy against HMDA data can be relied on.
• For this Fair Lending Redlining and HMDA Data file, read geographic application and origination heat map against a marketing mailer that skipped majority-minority tracts 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 (geographic application and origination heat map after a marketing mailer that skipped majority-minority tracts). Lead with the Fair Lending option geographic application and origination heat map can support after a marketing mailer that skipped majority-minority tracts, then the two facts that force it, then the Monday action for community-development lender in a mortgage company after a pricing-regression spike.