Assess whether HMDA data can be relied on for the exam (dc7dd9)

Situation

In a bank with thin HMDA LAR quality, HMDA LAR validity and quality edits is the evidence after an underwriter chat that used coded language. Fair-lending officer has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending CRA and Special-Purpose Programs close using HMDA LAR validity and quality edits.

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 HMDA LAR validity and quality edits after an underwriter chat that used coded language.

Hypotheses to test

• Authorize Remove access or reverse the item now; HMDA LAR validity and quality edits already has the discriminator after an underwriter chat that used coded language.
• Keep Temporary compensating control in force until HMDA LAR validity and quality edits is completed after an underwriter chat that used coded language for fair-lending officer.
• Treat HMDA LAR validity and quality edits as Approve a documented exception because both readings appear after an underwriter chat that used coded language.
• Refuse a Fair Lending close: fair-lending officer does not have the page HMDA data can be relied on turns on in HMDA LAR validity and quality edits.

Analysis required

• Check HMDA coding and underwriting policy against HMDA data can be relied on.
• Compare HMDA LAR validity and quality edits to similarly situated files, second-review notes, and reason codes after an underwriter chat that used coded language.
• Flag any disparate-impact table fair-lending officer cannot explain from HMDA LAR validity and quality edits.
• For this Fair Lending CRA and Special-Purpose Programs file, read HMDA LAR validity and quality edits against an underwriter chat that used coded language 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 (HMDA LAR validity and quality edits after an underwriter chat that used coded language). Lead with the Fair Lending option HMDA LAR validity and quality edits can support after an underwriter chat that used coded language, then the two facts that force it, then the Monday action for fair-lending officer in a bank with thin HMDA LAR quality.