Assess whether HMDA data can be relied on for the exam (3878dd)

Situation

After a HMDA resubmission that still fails quality edits, mortgage pricing residual by prohibited-basis group is what community-development lender can touch in a manufactured-housing lender with dealer-originated files. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this Examination and Notices file.

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

Hypotheses to test

• 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.
• 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 community-development lender.
• 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.
• Refuse a Fair Lending close: community-development lender 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 HMDA resubmission that still fails quality edits.
• 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 HMDA data can be relied on for community-development lender.

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). 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 community-development lender in a manufactured-housing lender with dealer-originated files.