Community-development lender must resolve whether a model update needs

Situation

Community-development lender owns a model update needs inside a bank with thin HMDA LAR quality with manufactured-housing dealer overlay notes as the only packet. A HMDA resubmission that still fails quality edits is what changed the clock for this Fair Lending Pricing and Credit Limits file.

Decision

Community-development lender in a bank with thin HMDA LAR quality must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using manufactured-housing dealer overlay notes after a HMDA resubmission that still fails quality edits.

Hypotheses to test

• Authorize Remove access or reverse the item now; manufactured-housing dealer overlay notes already has the discriminator after a HMDA resubmission that still fails quality edits.
• Keep Temporary compensating control in force until manufactured-housing dealer overlay notes is completed after a HMDA resubmission that still fails quality edits for community-development lender.
• Treat manufactured-housing dealer overlay notes 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 a model update needs turns on in manufactured-housing dealer overlay notes.

Analysis required

• Compare manufactured-housing dealer overlay notes 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 manufactured-housing dealer overlay notes.
• Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend.
• For this Fair Lending Pricing and Credit Limits file, read manufactured-housing dealer overlay notes against a HMDA resubmission that still fails quality edits and write the one fact that would move a model update needs for community-development lender.

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 HMDA resubmission that still fails quality edits). If manufactured-housing dealer overlay notes cannot force a Fair Lending label under Pricing and Credit Limits, stop. Do not invent pages a bank with thin HMDA LAR quality does not have.