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

Situation

Community-development lender owns HMDA data can be relied on inside a mortgage company after a pricing-regression spike with mortgage pricing residual by prohibited-basis group as the only packet. A SPCP that originated almost no loans to the intended class is what changed the clock for this Fair Lending Redlining and HMDA Data file.

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 mortgage pricing residual by prohibited-basis group after a SPCP that originated almost no loans to the intended class.

Hypotheses to test

• Community-development lender can defend Remove access or reverse the item from mortgage pricing residual by prohibited-basis group after a SPCP that originated almost no loans to the intended class in a Fair Lending challenge.
• Community-development lender cannot defend Remove access or reverse the item from mortgage pricing residual by prohibited-basis group; Temporary compensating control is what the extract actually supports after a SPCP that originated almost no loans to the intended class.
• A SPCP that originated almost no loans to the intended class never reached the population in mortgage pricing residual by prohibited-basis group — reopen intake, do not close HMDA data can be relied on.
• Two facts in mortgage pricing residual by prohibited-basis group after a SPCP that originated almost no loans to the intended class conflict for community-development lender; hold this Redlining and HMDA Data file.

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 mortgage pricing residual by prohibited-basis group.
• Check HMDA coding and underwriting policy against HMDA data can be relied on.
• For this Fair Lending Redlining and HMDA Data file, read mortgage pricing residual by prohibited-basis group against a SPCP that originated almost no loans to the intended class and write the one fact that would move HMDA data can be relied on for community-development lender.

Recommendation