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During a disclosure desk review, a disclosure specialist encounters an HMDA Fair Lending Analysis issue. Which response should avoid a shortcut that would misapply the rule?

Correct Answer

D) Use Regulation C coverage rules before excluding the file

Covered institutions collect and report HMDA data for covered mortgage applications and loans. The best answer is "Use Regulation C coverage rules before excluding the file".

Answer Options
A
Use an internal exception instead of the required federal disclosure or timing rule.
B
Use the licensing standard to decide the HMDA Fair Lending Analysis issue before confirming the trigger facts.
C
Rely on oral agreement when the rule requires documented compliance.
D
Use Regulation C coverage rules before excluding the file

Why This Is the Correct Answer

Covered institutions collect and report HMDA data for covered mortgage applications and loans. The best answer is "Use Regulation C coverage rules before excluding the file".

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