Assess whether HMDA data can be relied on for the exam (83c59f)

Situation

A DOJ or CFPB monitor request for pricing files put manufactured-housing dealer overlay notes in front of HMDA data-quality manager in a credit-card issuer changing line-assignment logic. This Fair Lending / Redlining and HMDA Data close is HMDA data can be relied on from manufactured-housing dealer overlay notes, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

Decision

HMDA data-quality manager in a credit-card issuer changing line-assignment logic must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using manufactured-housing dealer overlay notes after a DOJ or CFPB monitor request for pricing files.

Hypotheses to test

• The population in manufactured-housing dealer overlay notes is the one a DOJ or CFPB monitor request for pricing files named, so Remove access or reverse the item follows for this Redlining and HMDA Data file.
• The population in manufactured-housing dealer overlay notes is adjacent only to a DOJ or CFPB monitor request for pricing files; Temporary compensating control is the honest Fair Lending call.
• A credit-card issuer changing line-assignment logic already contained a DOJ or CFPB monitor request for pricing files before manufactured-housing dealer overlay notes arrived; no new Redlining and HMDA Data path.
• Provenance on manufactured-housing dealer overlay notes after a DOJ or CFPB monitor request for pricing files is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Test a documented exception versus a pattern a credit-card issuer changing line-assignment logic must defend.
• Match the adverse-action language to the facts in manufactured-housing dealer overlay notes.
• Check HMDA coding and underwriting policy against HMDA data can be relied on.
• For this Fair Lending Redlining and HMDA Data file, read manufactured-housing dealer overlay notes against a DOJ or CFPB monitor request for pricing files and write the one fact that would move HMDA data can be relied on 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 / Redlining and HMDA Data packet (manufactured-housing dealer overlay notes after a DOJ or CFPB monitor request for pricing files). If manufactured-housing dealer overlay notes cannot force a Fair Lending label under Redlining and HMDA Data, stop. If manufactured-housing dealer overlay notes after a DOJ or CFPB monitor request for pricing files cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending Redlining and HMDA Data close, HMDA data-quality manager must do not infer a control or scheme beyond the transaction and entitlement evidence.