Whether comparative files show second-review bias from manufactured-housing

Situation

Comparative files show second-review sits with HMDA data-quality manager because an underwriter chat that used coded language hit a lender expanding into majority-minority census tracts. Evidence is manufactured-housing dealer overlay notes; write the Fair Lending Pricing and Credit Limits option that extract can carry.

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 manufactured-housing dealer overlay notes after an underwriter chat that used coded language.

Hypotheses to test

• Manufactured-housing dealer overlay notes reads as Remove access or reverse the item once an underwriter chat that used coded language is lined up to the same Fair Lending population.
• Manufactured-housing dealer overlay notes is closer to Temporary compensating control after an underwriter chat that used coded language; Remove access or reverse the item would over-claim this Pricing and Credit Limits extract.
• Approve a documented exception is still live in manufactured-housing dealer overlay notes for HMDA data-quality manager in a lender expanding into majority-minority census tracts.
• Manufactured-housing dealer overlay notes is missing the fact HMDA data-quality manager needs after an underwriter chat that used coded language; stop this Fair Lending close.

Analysis required

• Check HMDA coding and underwriting policy against comparative files show second-review.
• Compare manufactured-housing dealer overlay notes to similarly situated files, second-review notes, and reason codes after an underwriter chat that used coded language.
• Flag any disparate-impact table HMDA data-quality manager cannot explain from manufactured-housing dealer overlay notes.
• For this Fair Lending Pricing and Credit Limits file, read manufactured-housing dealer overlay notes against an underwriter chat that used coded language and write the one fact that would move comparative files show second-review 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 (manufactured-housing dealer overlay notes after an underwriter chat that used coded language). Lead with the Fair Lending option manufactured-housing dealer overlay notes can support after an underwriter chat that used coded language, 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.