Assess whether a redlining pattern exists after controls (c7a28e)

Situation

Model-risk partner for credit scoring in a lender expanding into majority-minority census tracts has one working extract — manufactured-housing dealer overlay notes — after a HMDA resubmission that still fails quality edits. If manufactured-housing dealer overlay notes cannot support a redlining pattern exists, the honest Fair Lending output is hold.

Decision

Model-risk partner for credit scoring 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 HMDA resubmission that still fails quality edits.

Hypotheses to test

• Manufactured-housing dealer overlay notes reads as Remove access or reverse the item once a HMDA resubmission that still fails quality edits is lined up to the same Fair Lending population.
• Manufactured-housing dealer overlay notes is closer to Temporary compensating control after a HMDA resubmission that still fails quality edits; Remove access or reverse the item would over-claim this Examination and Notices extract.
• Approve a documented exception is still live in manufactured-housing dealer overlay notes for model-risk partner for credit scoring in a lender expanding into majority-minority census tracts.
• Manufactured-housing dealer overlay notes is missing the fact model-risk partner for credit scoring needs after a HMDA resubmission that still fails quality edits; stop this Fair Lending close.

Analysis required

• Check HMDA coding and underwriting policy against a redlining pattern exists.
• 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 model-risk partner for credit scoring cannot explain from manufactured-housing dealer overlay notes.
• For this Fair Lending Examination and Notices 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 redlining pattern exists for model-risk partner for credit scoring.

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 HMDA resubmission that still fails quality edits). Lead with the Fair Lending option manufactured-housing dealer overlay notes can support after a HMDA resubmission that still fails quality edits, then the two facts that force it, then the Monday action for model-risk partner for credit scoring in a lender expanding into majority-minority census tracts.