Assess whether line assignments have a disparate impact the bank will defend

Situation

Fair-lending officer in a manufactured-housing lender with dealer-originated files has one working extract — manufactured-housing dealer overlay notes — after a HMDA resubmission that still fails quality edits. If manufactured-housing dealer overlay notes cannot support line assignments have a, the honest Fair Lending output is hold.

Decision

Fair-lending officer 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 manufactured-housing dealer overlay notes after a HMDA resubmission that still fails quality edits.

Hypotheses to test

• Manufactured-housing dealer overlay notes reads as Remove access or reverse the item once a HMDA resubmission that still fails quality edits is lined up to the same Fair Lending population.
• Manufactured-housing dealer overlay notes is closer to Temporary compensating control after a HMDA resubmission that still fails quality edits; Remove access or reverse the item would over-claim this Redlining and HMDA Data extract.
• Approve a documented exception is still live in manufactured-housing dealer overlay notes for fair-lending officer in a manufactured-housing lender with dealer-originated files.
• Manufactured-housing dealer overlay notes is missing the fact fair-lending officer needs after a HMDA resubmission that still fails quality edits; stop this Fair Lending close.

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 manufactured-housing dealer overlay notes.
• Check HMDA coding and underwriting policy against line assignments have a.
• For this Fair Lending Redlining and HMDA Data file, read manufactured-housing dealer overlay notes against a HMDA resubmission that still fails quality edits and write the one fact that would move line assignments have a for fair-lending officer.

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 (manufactured-housing dealer overlay notes after a HMDA resubmission that still fails quality edits). Lead with the Fair Lending option manufactured-housing dealer overlay notes can support after a HMDA resubmission that still fails quality edits, then the two facts that force it, then the Monday action for fair-lending officer in a manufactured-housing lender with dealer-originated files.