Assess whether HMDA data can be relied on for the exam (c61228)

Situation

HMDA data can be relied on sits with adverse-action notice operations lead because a marketing mailer that skipped majority-minority tracts hit a credit-card issuer changing line-assignment logic. Evidence is SPCP written plan versus actual originations; write the Fair Lending Examination and Notices option that extract can carry.

Decision

Adverse-action notice operations lead in a credit-card issuer changing line-assignment logic 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 marketing mailer that skipped majority-minority tracts.

Hypotheses to test

• Adverse-action notice operations lead can defend Remove access or reverse the item from SPCP written plan versus actual originations after a marketing mailer that skipped majority-minority tracts in a Fair Lending challenge.
• Adverse-action notice operations lead 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 marketing mailer that skipped majority-minority tracts.
• A marketing mailer that skipped majority-minority tracts 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 marketing mailer that skipped majority-minority tracts conflict for adverse-action notice operations lead; hold this Examination and Notices file.

Analysis required

• Flag any disparate-impact table adverse-action notice operations lead cannot explain from SPCP written plan versus actual originations.
• Test a documented exception versus a pattern a credit-card issuer changing line-assignment logic must defend.
• Match the adverse-action language to the facts in SPCP written plan versus actual originations.
• For this Fair Lending Examination and Notices file, read SPCP written plan versus actual originations against a marketing mailer that skipped majority-minority tracts and write the one fact that would move HMDA data can be relied on for adverse-action notice operations lead.

Recommendation