Assess whether HMDA data can be relied on for the exam (f314fb)

Situation

A HMDA resubmission that still fails quality edits put model-reason-code mapping that does not match notices in front of community-development lender in a manufactured-housing lender with dealer-originated files. This Fair Lending / Examination and Notices close is HMDA data can be relied on from model-reason-code mapping that does not match notices, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

Decision

Community-development lender 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 model-reason-code mapping that does not match notices after a HMDA resubmission that still fails quality edits.

Hypotheses to test

• Community-development lender can defend Remove access or reverse the item from model-reason-code mapping that does not match notices after a HMDA resubmission that still fails quality edits in a Fair Lending challenge.
• Community-development lender cannot defend Remove access or reverse the item from model-reason-code mapping that does not match notices; Temporary compensating control is what the extract actually supports after a HMDA resubmission that still fails quality edits.
• A HMDA resubmission that still fails quality edits never reached the population in model-reason-code mapping that does not match notices — reopen intake, do not close HMDA data can be relied on.
• Two facts in model-reason-code mapping that does not match notices after a HMDA resubmission that still fails quality edits conflict for community-development lender; hold this Examination and Notices file.

Analysis required

• Check HMDA coding and underwriting policy against HMDA data can be relied on.
• Compare model-reason-code mapping that does not match notices to similarly situated files, second-review notes, and reason codes after a HMDA resubmission that still fails quality edits.
• Flag any disparate-impact table community-development lender cannot explain from model-reason-code mapping that does not match notices.
• For this Fair Lending Examination and Notices file, read model-reason-code mapping that does not match notices against a HMDA resubmission that still fails quality edits and write the one fact that would move HMDA data can be relied on for community-development lender.