Fair-lending officer must resolve whether HMDA data can be relied on

Situation

SPCP written plan versus actual originations arrived with a community complaint about appraisal gaps for fair-lending officer. That is a Fair Lending Pricing and Credit Limits decision on HMDA data can be relied on in a mortgage company after a pricing-regression spike.

Decision

Fair-lending officer 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 SPCP written plan versus actual originations after a community complaint about appraisal gaps.

Hypotheses to test

• Fair-lending officer can defend Remove access or reverse the item from SPCP written plan versus actual originations after a community complaint about appraisal gaps in a Fair Lending challenge.
• Fair-lending officer cannot defend Remove access or reverse the item from SPCP written plan versus actual originations; Temporary compensating control is what the extract actually supports after a community complaint about appraisal gaps.
• A community complaint about appraisal gaps never reached the population in SPCP written plan versus actual originations — reopen intake, do not close HMDA data can be relied on.
• Two facts in SPCP written plan versus actual originations after a community complaint about appraisal gaps conflict for fair-lending officer; hold this Pricing and Credit Limits file.

Analysis required

• Compare SPCP written plan versus actual originations to similarly situated files, second-review notes, and reason codes after a community complaint about appraisal gaps.
• Flag any disparate-impact table fair-lending officer cannot explain from SPCP written plan versus actual originations.
• Test a documented exception versus a pattern a mortgage company after a pricing-regression spike must defend.
• For this Fair Lending Pricing and Credit Limits file, read SPCP written plan versus actual originations against a community complaint about appraisal gaps 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 / Pricing and Credit Limits packet (SPCP written plan versus actual originations after a community complaint about appraisal gaps). If SPCP written plan versus actual originations cannot force a Fair Lending label under Pricing and Credit Limits, stop. Do not invent pages a mortgage company after a pricing-regression spike does not have.