Second-review underwriter must resolve whether HMDA data can be relied on

Situation

Second-review underwriter in a small-business desk using a new vendor score has one working extract — mortgage pricing residual by prohibited-basis group — after a branch that stopped taking applications in one ZIP. If mortgage pricing residual by prohibited-basis group cannot support HMDA data can be relied on, the honest Fair Lending output is hold.

Decision

Second-review underwriter in a small-business desk using a new vendor score 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 branch that stopped taking applications in one ZIP.

Hypotheses to test

• Authorize Remove access or reverse the item now; mortgage pricing residual by prohibited-basis group already has the discriminator after a branch that stopped taking applications in one ZIP.
• Keep Temporary compensating control in force until mortgage pricing residual by prohibited-basis group is completed after a branch that stopped taking applications in one ZIP for second-review underwriter.
• Treat mortgage pricing residual by prohibited-basis group as Approve a documented exception because both readings appear after a branch that stopped taking applications in one ZIP.
• Refuse a Fair Lending close: second-review underwriter does not have the page HMDA data can be relied on turns on in mortgage pricing residual by prohibited-basis group.

Analysis required

• Match the adverse-action language to the facts in mortgage pricing residual by prohibited-basis group.
• Check HMDA coding and underwriting policy against HMDA data can be relied on.
• Compare mortgage pricing residual by prohibited-basis group to similarly situated files, second-review notes, and reason codes after a branch that stopped taking applications in one ZIP.
• For this Fair Lending Redlining and HMDA Data file, read mortgage pricing residual by prohibited-basis group against a branch that stopped taking applications in one ZIP and write the one fact that would move HMDA data can be relied on for second-review underwriter.

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 (mortgage pricing residual by prohibited-basis group after a branch that stopped taking applications in one ZIP). If mortgage pricing residual by prohibited-basis group cannot force a Fair Lending label under Redlining and HMDA Data, stop. If mortgage pricing residual by prohibited-basis group after a branch that stopped taking applications in one ZIP cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending Redlining and HMDA Data close, second-review underwriter must do not infer a control or scheme beyond the transaction and entitlement evidence.