Whether the exam response should concede a finding from mortgage pricing

SITUATION Pricing and Credit Limits work in a lender expanding into majority-minority census tracts now turns on the exam response should because a HMDA resubmission that still fails quality edits put mortgage pricing residual by prohibited-basis group in play. HMDA data-quality manager should say what mortgage pricing residual by prohibited-basis group proves.

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 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 HMDA data-quality manager. 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: HMDA data-quality manager does not have the decision the exam response should turns on in mortgage pricing residual by prohibited-basis group.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern a lender expanding into majority-minority census tracts must defend. 2. Match the adverse-action language to the facts in mortgage pricing residual by prohibited-basis group. 3. Check HMDA coding and underwriting policy against the exam response should. 4. For this Fair Lending Pricing and Credit Limits 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 the exam response should 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 (mortgage pricing residual by prohibited-basis group after a HMDA resubmission that still fails quality edits). Lead with the Fair Lending option mortgage pricing residual by prohibited-basis group can support after a HMDA resubmission that still fails quality edits, 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.

COMMAND RETURNS - Bottom-line Fair Lending option on the exam response should, then the evidence in mortgage pricing residual by prohibited-basis group, then the action for HMDA data-quality manager - Hypothesis scorecard against mortgage pricing residual by prohibited-basis group: supported / rejected / untestable - Owner and next date for HMDA data-quality manager in a lender expanding into majority-minority census tracts - What changes the exam response should if a HMDA resubmission that still fails quality edits is later withdrawn