Assess whether to pause a product pending a lookback after a HMDA

SITUATION The Redlining and HMDA Data working file is small-business decline comparative file set after a HMDA resubmission that still fails quality edits. Fair-lending officer in a manufactured-housing lender with dealer-originated files must name Remove access or reverse the item or Temporary compensating control for this Fair Lending file. Fair-lending officer in a manufactured-housing lender with dealer-originated files has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending Redlining and HMDA Data file.

DECISION Fair-lending officer 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 small-business decline comparative file set after a HMDA resubmission that still fails quality edits.

HYPOTHESES TO TEST 1. 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. 2. 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 fair-lending officer. 3. 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. 4. Refuse a Fair Lending close: fair-lending officer does not have the decision to pause a product turns on in small-business decline comparative file set.

ANALYSIS REQUIRED 1. Flag any disparate-impact table fair-lending officer cannot explain from small-business decline comparative file set. 2. Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend. 3. Match the adverse-action language to the facts in small-business decline comparative file set. 4. For this Fair Lending Redlining and HMDA Data 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 to pause a product for fair-lending officer.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Redlining and HMDA Data packet (small-business decline comparative file set after a HMDA resubmission that still fails quality edits). The follow-on Redlining and HMDA Data action is what fair-lending officer 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 small-business decline comparative file set, then the action for fair-lending officer - Hypothesis scorecard against small-business decline comparative file set: supported / rejected / untestable - Regulatory or exam hook Redlining and HMDA Data would cite - Redlining and HMDA Data finding in small-business decline comparative file set that a second reviewer can re-perform