HMDA data-quality manager must resolve whether a model update needs

Situation

After a DOJ or CFPB monitor request for pricing files, manufactured-housing dealer overlay notes is what HMDA data-quality manager can touch in a lender expanding into majority-minority census tracts. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this Pricing and Credit Limits file.

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 manufactured-housing dealer overlay notes after a DOJ or CFPB monitor request for pricing files.

Hypotheses to test

• The population in manufactured-housing dealer overlay notes is the one a DOJ or CFPB monitor request for pricing files named, so Remove access or reverse the item follows for this Pricing and Credit Limits file.
• The population in manufactured-housing dealer overlay notes is adjacent only to a DOJ or CFPB monitor request for pricing files; Temporary compensating control is the honest Fair Lending call.
• A lender expanding into majority-minority census tracts already contained a DOJ or CFPB monitor request for pricing files before manufactured-housing dealer overlay notes arrived; no new Pricing and Credit Limits path.
• Provenance on manufactured-housing dealer overlay notes after a DOJ or CFPB monitor request for pricing files is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Match the adverse-action language to the facts in manufactured-housing dealer overlay notes.
• Check HMDA coding and underwriting policy against a model update needs.
• Compare manufactured-housing dealer overlay notes to similarly situated files, second-review notes, and reason codes after a DOJ or CFPB monitor request for pricing files.
• For this Fair Lending Pricing and Credit Limits file, read manufactured-housing dealer overlay notes against a DOJ or CFPB monitor request for pricing files and write the one fact that would move a model update needs 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 (manufactured-housing dealer overlay notes after a DOJ or CFPB monitor request for pricing files). Lead with the Fair Lending option manufactured-housing dealer overlay notes can support after a DOJ or CFPB monitor request for pricing files, 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.