Assess whether comparative files show second-review bias (bdfec3)

Situation

In a small-business desk using a new vendor score, manufactured-housing dealer overlay notes is the evidence after a community complaint about appraisal gaps. HMDA data-quality manager has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending Examination and Notices close using manufactured-housing dealer overlay notes.

Decision

HMDA data-quality manager in a small-business desk using a new vendor score must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using manufactured-housing dealer overlay notes after a community complaint about appraisal gaps.

Hypotheses to test

• Manufactured-housing dealer overlay notes lines up with a community complaint about appraisal gaps for Remove access or reverse the item on comparative files show second-review; HMDA data-quality manager in a small-business desk using a new vendor score can execute that path.
• Manufactured-housing dealer overlay notes conflicts with a community complaint about appraisal gaps for Remove access or reverse the item, so Temporary compensating control is the Fair Lending move on this Examination and Notices packet.
• Flag any disparate-impact table HMDA data-quality manager cannot explain from manufactured-housing dealer overlay notes. would move comparative files show second-review only if it appears in manufactured-housing dealer overlay notes after a community complaint about appraisal gaps.
• HMDA data-quality manager should treat manufactured-housing dealer overlay notes as incomplete for comparative files show second-review rather than borrow a label from another a small-business desk using a new vendor score file.

Analysis required

• Flag any disparate-impact table HMDA data-quality manager cannot explain from manufactured-housing dealer overlay notes.
• Test a documented exception versus a pattern a small-business desk using a new vendor score must defend.
• Match the adverse-action language to the facts in manufactured-housing dealer overlay notes.
• For this Fair Lending Examination and Notices file, read manufactured-housing dealer overlay notes against a community complaint about appraisal gaps and write the one fact that would move comparative files show second-review for HMDA data-quality manager.