Assess whether HMDA data can be relied on for the exam (8d5a47)

Situation

Model-reason-code mapping that does not match notices arrived with a marketing mailer that skipped majority-minority tracts for fair-lending officer. That is a Fair Lending CRA and Special-Purpose Programs decision on HMDA data can be relied on in a bank with thin HMDA LAR quality.

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 model-reason-code mapping that does not match notices after a marketing mailer that skipped majority-minority tracts.

Hypotheses to test

• Fair-lending officer can defend Remove access or reverse the item from model-reason-code mapping that does not match notices after a marketing mailer that skipped majority-minority tracts in a Fair Lending challenge.
• Fair-lending officer cannot defend Remove access or reverse the item from model-reason-code mapping that does not match notices; Temporary compensating control is what the extract actually supports after a marketing mailer that skipped majority-minority tracts.
• A marketing mailer that skipped majority-minority tracts never reached the population in model-reason-code mapping that does not match notices — reopen intake, do not close HMDA data can be relied on.
• Two facts in model-reason-code mapping that does not match notices after a marketing mailer that skipped majority-minority tracts conflict for fair-lending officer; hold this CRA and Special-Purpose Programs file.

Analysis required

• Match the adverse-action language to the facts in model-reason-code mapping that does not match notices.
• Check HMDA coding and underwriting policy against HMDA data can be relied on.
• Compare model-reason-code mapping that does not match notices to similarly situated files, second-review notes, and reason codes after a marketing mailer that skipped majority-minority tracts.
• For this Fair Lending CRA and Special-Purpose Programs file, read model-reason-code mapping that does not match notices against a marketing mailer that skipped majority-minority tracts 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 (model-reason-code mapping that does not match notices after a marketing mailer that skipped majority-minority tracts). If model-reason-code mapping that does not match notices cannot force a Fair Lending label under CRA and Special-Purpose Programs, stop. If model-reason-code mapping that does not match notices after a marketing mailer that skipped majority-minority tracts 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.