Assess whether notices match the actual decisioning reasons (efb330)

SITUATION After a vendor score change with no disparate-impact test, manufactured-housing dealer overlay notes 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 manufactured-housing dealer overlay notes after a vendor score change with no disparate-impact test.

HYPOTHESES TO TEST 1. The population in manufactured-housing dealer overlay notes is the one a vendor score change with no disparate-impact test named, so Remove access or reverse the item follows for this Examination and Notices file. 2. The population in manufactured-housing dealer overlay notes is adjacent only to a vendor score change with no disparate-impact test; Temporary compensating control is the honest Fair Lending call. 3. A manufactured-housing lender with dealer-originated files already contained a vendor score change with no disparate-impact test before manufactured-housing dealer overlay notes arrived; no new Examination and Notices path. 4. Provenance on manufactured-housing dealer overlay notes after a vendor score change with no disparate-impact test is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against notices match the actual. 2. Compare manufactured-housing dealer overlay notes to similarly situated files, second-review notes, and reason codes after a vendor score change with no disparate-impact test. 3. Flag any disparate-impact table community-development lender cannot explain from manufactured-housing dealer overlay notes. 4. For this Fair Lending Examination and Notices file, read manufactured-housing dealer overlay notes against a vendor score change with no disparate-impact test and write the one fact that would move notices match the actual 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 (manufactured-housing dealer overlay notes after a vendor score change with no disparate-impact test). If manufactured-housing dealer overlay notes cannot force a Fair Lending label under Examination and Notices, stop. Do not invent missing evidence a manufactured-housing lender with dealer-originated files does not have.