Assess whether HMDA data can be relied on for the exam (9cbbde)

Situation

Small-business decline comparative file set arrived with a marketing mailer that skipped majority-minority tracts for exam-response coordinator. That is a Fair Lending Redlining and HMDA Data decision on HMDA data can be relied on in a bank with thin HMDA LAR quality.

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 marketing mailer that skipped majority-minority tracts.

Hypotheses to test

• The population in small-business decline comparative file set 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 small-business decline comparative file set is adjacent only to a marketing mailer that skipped majority-minority tracts; Temporary compensating control is the honest Fair Lending call.
• A bank with thin HMDA LAR quality already contained a marketing mailer that skipped majority-minority tracts before small-business decline comparative file set arrived; no new Redlining and HMDA Data path.
• Provenance on small-business decline comparative file set 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

• 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 marketing mailer that skipped majority-minority tracts 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 marketing mailer that skipped majority-minority tracts). The follow-on Redlining and HMDA Data action is what exam-response coordinator does next: implement the option, assign an owner, and log the missing fact.