Assess whether HMDA data can be relied on for the exam (75896e)

Situation

Exam-response coordinator owns HMDA data can be relied on inside a bank with thin HMDA LAR quality with small-business decline comparative file set as the only packet. A board asking if the bank should settle a matched-pair study is what changed the clock for this Fair Lending Redlining and HMDA Data file.

Decision

Exam-response coordinator 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 small-business decline comparative file set after a board asking if the bank should settle a matched-pair study.

Hypotheses to test

• Exam-response coordinator can defend Remove access or reverse the item from small-business decline comparative file set after a board asking if the bank should settle a matched-pair study in a Fair Lending challenge.
• Exam-response coordinator cannot defend Remove access or reverse the item from small-business decline comparative file set; Temporary compensating control is what the extract actually supports after a board asking if the bank should settle a matched-pair study.
• A board asking if the bank should settle a matched-pair study never reached the population in small-business decline comparative file set — reopen intake, do not close HMDA data can be relied on.
• Two facts in small-business decline comparative file set after a board asking if the bank should settle a matched-pair study conflict for exam-response coordinator; hold this Redlining and HMDA Data file.

Analysis required

• Flag any disparate-impact table exam-response coordinator cannot explain from small-business decline comparative file set.
• Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend.
• Match the adverse-action language to the facts in small-business decline comparative file set.
• For this Fair Lending Redlining and HMDA Data file, read small-business decline comparative file set against a board asking if the bank should settle a matched-pair study 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 / Redlining and HMDA Data packet (small-business decline comparative file set after a board asking if the bank should settle a matched-pair study). Lead with the Fair Lending option small-business decline comparative file set can support after a board asking if the bank should settle a matched-pair study, then the two facts that force it, then the Monday action for exam-response coordinator in a bank with thin HMDA LAR quality.