Assess whether HMDA data can be relied on for the exam (827836)

Situation

After a DOJ or CFPB monitor request for pricing files, underwriting exception log by branch is what community-development lender can touch in a mortgage company after a pricing-regression spike. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this Redlining and HMDA Data file.

Decision

Community-development lender 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 underwriting exception log by branch after a DOJ or CFPB monitor request for pricing files.

Hypotheses to test

• Authorize Remove access or reverse the item now; underwriting exception log by branch already has the discriminator after a DOJ or CFPB monitor request for pricing files.
• Keep Temporary compensating control in force until underwriting exception log by branch is completed after a DOJ or CFPB monitor request for pricing files for community-development lender.
• Treat underwriting exception log by branch as Approve a documented exception because both readings appear after a DOJ or CFPB monitor request for pricing files.
• Refuse a Fair Lending close: community-development lender does not have the page HMDA data can be relied on turns on in underwriting exception log by branch.

Analysis required

• Check HMDA coding and underwriting policy against HMDA data can be relied on.
• Compare underwriting exception log by branch to similarly situated files, second-review notes, and reason codes after a DOJ or CFPB monitor request for pricing files.
• Flag any disparate-impact table community-development lender cannot explain from underwriting exception log by branch.
• For this Fair Lending Redlining and HMDA Data file, read underwriting exception log by branch against a DOJ or CFPB monitor request for pricing files and write the one fact that would move HMDA data can be relied on for community-development lender.

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 (underwriting exception log by branch after a DOJ or CFPB monitor request for pricing files). Lead with the Fair Lending option underwriting exception log by branch can support after a DOJ or CFPB monitor request for pricing files, then the two facts that force it, then the Monday action for community-development lender in a mortgage company after a pricing-regression spike.