HMDA data-quality manager must resolve whether dealer overlays introduce

Situation

In a lender expanding into majority-minority census tracts, geographic application and origination heat map is the evidence after a HMDA resubmission that still fails quality edits. HMDA data-quality manager has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending Pricing and Credit Limits close using geographic application and origination heat map.

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 geographic application and origination heat map after a HMDA resubmission that still fails quality edits.

Hypotheses to test

• HMDA data-quality manager can defend Remove access or reverse the item from geographic application and origination heat map after a HMDA resubmission that still fails quality edits in a Fair Lending challenge.
• HMDA data-quality manager cannot defend Remove access or reverse the item from geographic application and origination heat map; Temporary compensating control is what the extract actually supports after a HMDA resubmission that still fails quality edits.
• A HMDA resubmission that still fails quality edits never reached the population in geographic application and origination heat map — reopen intake, do not close dealer overlays introduce prohibited.
• Two facts in geographic application and origination heat map after a HMDA resubmission that still fails quality edits conflict for HMDA data-quality manager; hold this Pricing and Credit Limits file.

Analysis required

• Compare geographic application and origination heat map 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 geographic application and origination heat map.
• Test a documented exception versus a pattern a lender expanding into majority-minority census tracts must defend.
• For this Fair Lending Pricing and Credit Limits file, read geographic application and origination heat map against a HMDA resubmission that still fails quality edits and write the one fact that would move dealer overlays introduce prohibited for HMDA data-quality manager.