Assess whether HMDA data can be relied on for the exam (9c1bb5)

Situation

After a CRA PE that called the assessment area too narrow, underwriting exception log by branch is what exam-response coordinator can touch in a manufactured-housing lender with dealer-originated files. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this CRA and Special-Purpose Programs file.

Decision

Exam-response coordinator in a manufactured-housing lender with dealer-originated files must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using underwriting exception log by branch after a CRA PE that called the assessment area too narrow.

Hypotheses to test

• Exam-response coordinator can defend Remove access or reverse the item from underwriting exception log by branch after a CRA PE that called the assessment area too narrow in a Fair Lending challenge.
• Exam-response coordinator cannot defend Remove access or reverse the item from underwriting exception log by branch; Temporary compensating control is what the extract actually supports after a CRA PE that called the assessment area too narrow.
• A CRA PE that called the assessment area too narrow never reached the population in underwriting exception log by branch — reopen intake, do not close HMDA data can be relied on.
• Two facts in underwriting exception log by branch after a CRA PE that called the assessment area too narrow conflict for exam-response coordinator; hold this CRA and Special-Purpose Programs file.

Analysis required

• Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend.
• Match the adverse-action language to the facts in underwriting exception log by branch.
• Check HMDA coding and underwriting policy against HMDA data can be relied on.
• For this Fair Lending CRA and Special-Purpose Programs file, read underwriting exception log by branch against a CRA PE that called the assessment area too narrow 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 / CRA and Special-Purpose Programs packet (underwriting exception log by branch after a CRA PE that called the assessment area too narrow). The follow-on CRA and Special-Purpose Programs action is what exam-response coordinator does next: implement the option, assign an owner, and log the missing fact.