HMDA data-quality manager must resolve whether line assignments have

Situation

The desk packet is SPCP written plan versus actual originations after a marketing mailer that skipped majority-minority tracts. HMDA data-quality manager in a lender expanding into majority-minority census tracts has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending Pricing and Credit Limits file.

Decision

HMDA data-quality manager in a lender expanding into majority-minority census tracts 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

• HMDA data-quality manager 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.
• HMDA data-quality manager 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 line assignments have a.
• Two facts in SPCP written plan versus actual originations after a marketing mailer that skipped majority-minority tracts conflict for HMDA data-quality manager; hold this Pricing and Credit Limits file.

Analysis required

• Match the adverse-action language to the facts in SPCP written plan versus actual originations.
• Check HMDA coding and underwriting policy against line assignments have a.
• Compare SPCP written plan versus actual originations to similarly situated files, second-review notes, and reason codes after a marketing mailer that skipped majority-minority tracts.
• For this Fair Lending Pricing and Credit Limits 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 line assignments have a for HMDA data-quality manager.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Pricing and Credit Limits packet (SPCP written plan versus actual originations after a marketing mailer that skipped majority-minority tracts). Lead with the Fair Lending option SPCP written plan versus actual originations can support after a marketing mailer that skipped majority-minority tracts, then the two facts that force it, then the Monday action for HMDA data-quality manager in a lender expanding into majority-minority census tracts.