Assess whether HMDA data can be relied on for the exam (2e46b5)

Situation

Fair-lending officer owns HMDA data can be relied on inside an institution preparing for a redlining exam with underwriting exception log by branch as the only packet. An underwriter chat that used coded language is what changed the clock for this Fair Lending Examination and Notices file.

Decision

Fair-lending officer in an institution preparing for a redlining exam must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using underwriting exception log by branch after an underwriter chat that used coded language.

Hypotheses to test

• The population in underwriting exception log by branch is the one an underwriter chat that used coded language named, so Remove access or reverse the item follows for this Examination and Notices file.
• The population in underwriting exception log by branch is adjacent only to an underwriter chat that used coded language; Temporary compensating control is the honest Fair Lending call.
• An institution preparing for a redlining exam already contained an underwriter chat that used coded language before underwriting exception log by branch arrived; no new Examination and Notices path.
• Provenance on underwriting exception log by branch 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

• Flag any disparate-impact table fair-lending officer cannot explain from underwriting exception log by branch.
• Test a documented exception versus a pattern an institution preparing for a redlining exam must defend.
• Match the adverse-action language to the facts in underwriting exception log by branch.
• For this Fair Lending Examination and Notices file, read underwriting exception log by branch against an underwriter chat that used coded language 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 / Examination and Notices packet (underwriting exception log by branch after an underwriter chat that used coded language). The follow-on Examination and Notices action is what fair-lending officer does next: implement the option, assign an owner, and log the missing fact.