Assess whether HMDA data can be relied on for the exam after an underwriter

Situation

SPCP written plan versus actual originations arrived with an underwriter chat that used coded language 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 SPCP written plan versus actual originations after an underwriter chat that used coded language.

Hypotheses to test

• The population in SPCP written plan versus actual originations is the one an underwriter chat that used coded language named, so Remove access or reverse the item follows for this Redlining and HMDA Data file.
• The population in SPCP written plan versus actual originations is adjacent only to an underwriter chat that used coded language; Temporary compensating control is the honest Fair Lending call.
• A bank with thin HMDA LAR quality already contained an underwriter chat that used coded language before SPCP written plan versus actual originations arrived; no new Redlining and HMDA Data path.
• Provenance on SPCP written plan versus actual originations after an underwriter chat that used coded language is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Match the adverse-action language to the facts in SPCP written plan versus actual originations.
• Check HMDA coding and underwriting policy against HMDA data can be relied on.
• Compare SPCP written plan versus actual originations to similarly situated files, second-review notes, and reason codes after an underwriter chat that used coded language.
• For this Fair Lending Redlining and HMDA Data file, read SPCP written plan versus actual originations against an underwriter chat that used coded language 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 (SPCP written plan versus actual originations after an underwriter chat that used coded language). 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.