Whether a redlining pattern exists after controls from small-business decline

Situation

The desk packet is small-business decline comparative file set after a HMDA resubmission that still fails quality edits. HMDA data-quality manager in a lender expanding into majority-minority census tracts has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending 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 small-business decline comparative file set after a HMDA resubmission that still fails quality edits.

Hypotheses to test

• Authorize Remove access or reverse the item now; small-business decline comparative file set already has the discriminator after a HMDA resubmission that still fails quality edits.
• Keep Temporary compensating control in force until small-business decline comparative file set is completed after a HMDA resubmission that still fails quality edits for HMDA data-quality manager.
• Treat small-business decline comparative file set as Approve a documented exception because both readings appear after a HMDA resubmission that still fails quality edits.
• Refuse a Fair Lending close: HMDA data-quality manager does not have the page a redlining pattern exists turns on in small-business decline comparative file set.

Analysis required

• Check HMDA coding and underwriting policy against a redlining pattern exists.
• Compare small-business decline comparative file set to similarly situated files, second-review notes, and reason codes after a HMDA resubmission that still fails quality edits.
• Flag any disparate-impact table HMDA data-quality manager cannot explain from small-business decline comparative file set.
• For this Fair Lending Pricing and Credit Limits file, read small-business decline comparative file set against a HMDA resubmission that still fails quality edits and write the one fact that would move a redlining pattern exists 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 (small-business decline comparative file set after a HMDA resubmission that still fails quality edits). Lead with the Fair Lending option small-business decline comparative file set can support after a HMDA resubmission that still fails quality edits, 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.