Assess whether a redlining pattern exists after controls (a79b0c)

Situation

A notice that cites 'other' as the principal reason 40% of the time put HMDA LAR validity and quality edits in front of exam-response coordinator in a manufactured-housing lender with dealer-originated files. This Fair Lending / CRA and Special-Purpose Programs close is a redlining pattern exists from HMDA LAR validity and quality edits, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

Decision

Exam-response coordinator 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 HMDA LAR validity and quality edits after a notice that cites 'other' as the principal reason 40% of the time.

Hypotheses to test

• The population in HMDA LAR validity and quality edits is the one a notice that cites 'other' as the principal reason 40% of the time named, so Remove access or reverse the item follows for this CRA and Special-Purpose Programs file.
• The population in HMDA LAR validity and quality edits is adjacent only to a notice that cites 'other' as the principal reason 40% of the time; Temporary compensating control is the honest Fair Lending call.
• A manufactured-housing lender with dealer-originated files already contained a notice that cites 'other' as the principal reason 40% of the time before HMDA LAR validity and quality edits arrived; no new CRA and Special-Purpose Programs path.
• Provenance on HMDA LAR validity and quality edits after a notice that cites 'other' as the principal reason 40% of the time is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Flag any disparate-impact table exam-response coordinator cannot explain from HMDA LAR validity and quality edits.
• Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend.
• Match the adverse-action language to the facts in HMDA LAR validity and quality edits.
• For this Fair Lending CRA and Special-Purpose Programs file, read HMDA LAR validity and quality edits against a notice that cites 'other' as the principal reason 40% of the time and write the one fact that would move a redlining pattern exists for exam-response coordinator.