Assess whether notices match the actual decisioning reasons (eb2b09)

SITUATION Fair-lending officer in an institution preparing for a redlining exam has one working extract — mortgage pricing residual by prohibited-basis group — after a HMDA resubmission that still fails quality edits. If mortgage pricing residual by prohibited-basis group cannot support notices match the actual, the only defensible Fair Lending output is hold.

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 mortgage pricing residual by prohibited-basis group after a HMDA resubmission that still fails quality edits.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; mortgage pricing residual by prohibited-basis group already has the discriminator after a HMDA resubmission that still fails quality edits. 2. Keep Temporary compensating control in force until mortgage pricing residual by prohibited-basis group is completed after a HMDA resubmission that still fails quality edits for fair-lending officer. 3. Treat mortgage pricing residual by prohibited-basis group as Approve a documented exception because both readings appear after a HMDA resubmission that still fails quality edits. 4. Refuse a Fair Lending close: fair-lending officer does not have the decision notices match the actual turns on in mortgage pricing residual by prohibited-basis group.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in mortgage pricing residual by prohibited-basis group. 2. Check HMDA coding and underwriting policy against notices match the actual. 3. Compare mortgage pricing residual by prohibited-basis group to similarly situated files, second-review notes, and reason codes after a HMDA resubmission that still fails quality edits. 4. For this Fair Lending Examination and Notices file, read mortgage pricing residual by prohibited-basis group against a HMDA resubmission that still fails quality edits and write the one fact that would move notices match the actual 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 (mortgage pricing residual by prohibited-basis group after a HMDA resubmission that still fails quality edits). 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.

COMMAND RETURNS - Bottom-line Fair Lending option on notices match the actual, then the evidence in mortgage pricing residual by prohibited-basis group, then the action for fair-lending officer - Hypothesis scorecard against mortgage pricing residual by prohibited-basis group: supported / rejected / untestable - Examination and Notices finding in mortgage pricing residual by prohibited-basis group that a second reviewer can re-perform - Missing page in mortgage pricing residual by prohibited-basis group after a HMDA resubmission that still fails quality edits, if any