Assess whether comparative files show second-review bias (101a02)

Situation

In an institution preparing for a redlining exam, manufactured-housing dealer overlay notes is the evidence after a HMDA resubmission that still fails quality edits. Fair-lending officer has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending Examination and Notices close using manufactured-housing dealer overlay notes.

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

Hypotheses to test

• Authorize Remove access or reverse the item now; manufactured-housing dealer overlay notes already has the discriminator after a HMDA resubmission that still fails quality edits.
• Keep Temporary compensating control in force until manufactured-housing dealer overlay notes is completed after a HMDA resubmission that still fails quality edits for fair-lending officer.
• Treat manufactured-housing dealer overlay notes as Approve a documented exception because both readings appear after a HMDA resubmission that still fails quality edits.
• Refuse a Fair Lending close: fair-lending officer does not have the page comparative files show second-review turns on in manufactured-housing dealer overlay notes.

Analysis required

• Flag any disparate-impact table fair-lending officer cannot explain from manufactured-housing dealer overlay notes.
• 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 manufactured-housing dealer overlay notes.
• For this Fair Lending Examination and Notices file, read manufactured-housing dealer overlay notes against a HMDA resubmission that still fails quality edits and write the one fact that would move comparative files show second-review 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 (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 an institution preparing for a redlining exam.