Whether to pause a product pending a lookback from manufactured-housing

SITUATION Community-development lender is responsible for to pause a product in a bank, using thin HMDA LAR quality with manufactured-housing dealer overlay notes as the only working extract. A HMDA resubmission that still fails quality edits is what reset the timeline 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 1. 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. 2. 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. 3. Treat manufactured-housing dealer overlay notes as Approve a documented exception because both readings appear after a HMDA resubmission that still fails quality edits. 4. Refuse a Fair Lending close: community-development lender does not have the decision to pause a product turns on in manufactured-housing dealer overlay notes.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against to pause a product. 2. 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. 3. Flag any disparate-impact table community-development lender cannot explain from manufactured-housing dealer overlay notes. 4. 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 to pause a product 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). The follow-on Pricing and Credit Limits action is what community-development lender does next: implement the option, assign an owner, and log the missing fact.

COMMAND RETURNS - Bottom-line Fair Lending option on to pause a product, then the evidence in manufactured-housing dealer overlay notes, then the action for community-development lender - Hypothesis scorecard against manufactured-housing dealer overlay notes: supported / rejected / untestable - Pricing and Credit Limits finding in manufactured-housing dealer overlay notes that a second reviewer can re-perform - Missing page in manufactured-housing dealer overlay notes after a HMDA resubmission that still fails quality edits, if any