Assess whether the exam response should concede a finding (5911e2)

SITUATION The working file is manufactured-housing dealer overlay notes after a HMDA resubmission that still fails quality edits. 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 manufactured-housing dealer overlay notes after a HMDA resubmission that still fails quality edits.

HYPOTHESES TO TEST 1. A HMDA resubmission that still fails quality edits is noise around an already-controlled Redlining and HMDA Data process in a manufactured-housing lender with dealer-originated files, given manufactured-housing dealer overlay notes. 2. A HMDA resubmission that still fails quality edits is the event in manufactured-housing dealer overlay notes that forces Remove access or reverse the item for fair-lending officer under Fair Lending. 3. Manufactured-housing dealer overlay notes shows a one-file miss after a HMDA resubmission that still fails quality edits, not a Redlining and HMDA Data program failure. 4. Manufactured-housing dealer overlay notes cannot decide the exam response should yet after a HMDA resubmission that still fails quality edits; hold is the only Fair Lending close a manufactured-housing lender with dealer-originated files can defend.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in manufactured-housing dealer overlay notes. 2. Check HMDA coding and underwriting policy against the exam response should. 3. Compare manufactured-housing dealer overlay notes to similarly situated files, second-review notes, and reason codes after a HMDA resubmission that still fails quality edits. 4. For this Fair Lending Redlining and HMDA Data file, read manufactured-housing dealer overlay notes against a HMDA resubmission that still fails quality edits and write the one fact that would move the exam response should 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 (manufactured-housing dealer overlay notes 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 the exam response should, then the evidence in manufactured-housing dealer overlay notes, then the action for fair-lending officer - Hypothesis scorecard against manufactured-housing dealer overlay notes: supported / rejected / untestable - Missing page in manufactured-housing dealer overlay notes after a HMDA resubmission that still fails quality edits, if any - Regulatory or exam hook Redlining and HMDA Data would cite