Assess whether comparative files show second-review bias (a22487)

Situation

Exam-response coordinator owns comparative files show second-review inside a manufactured-housing lender with dealer-originated files with adverse-action notice principal-reason sample as the only packet. A HMDA resubmission that still fails quality edits is what changed the clock for this Fair Lending CRA and Special-Purpose Programs file.

Decision

Exam-response coordinator 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 adverse-action notice principal-reason sample after a HMDA resubmission that still fails quality edits.

Hypotheses to test

• Exam-response coordinator can defend Remove access or reverse the item from adverse-action notice principal-reason sample after a HMDA resubmission that still fails quality edits in a Fair Lending challenge.
• Exam-response coordinator cannot defend Remove access or reverse the item from adverse-action notice principal-reason sample; 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 adverse-action notice principal-reason sample — reopen intake, do not close comparative files show second-review.
• Two facts in adverse-action notice principal-reason sample after a HMDA resubmission that still fails quality edits conflict for exam-response coordinator; hold this CRA and Special-Purpose Programs file.

Analysis required

• Flag any disparate-impact table exam-response coordinator cannot explain from adverse-action notice principal-reason sample.
• Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend.
• Match the adverse-action language to the facts in adverse-action notice principal-reason sample.
• For this Fair Lending CRA and Special-Purpose Programs file, read adverse-action notice principal-reason sample against a HMDA resubmission that still fails quality edits and write the one fact that would move comparative files show second-review for exam-response coordinator.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / CRA and Special-Purpose Programs packet (adverse-action notice principal-reason sample after a HMDA resubmission that still fails quality edits). Lead with the Fair Lending option adverse-action notice principal-reason sample can support after a HMDA resubmission that still fails quality edits, then the two facts that force it, then the Monday action for exam-response coordinator in a manufactured-housing lender with dealer-originated files.