Assess whether HMDA data can be relied on for the exam (98f35f)

Situation

CRA strategist in a mortgage company after a pricing-regression spike has one working extract — manufactured-housing dealer overlay notes — after a marketing mailer that skipped majority-minority tracts. If manufactured-housing dealer overlay notes cannot support HMDA data can be relied on, the honest Fair Lending output is hold.

Decision

CRA strategist in a mortgage company after a pricing-regression spike must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using manufactured-housing dealer overlay notes after a marketing mailer that skipped majority-minority tracts.

Hypotheses to test

• Authorize Remove access or reverse the item now; manufactured-housing dealer overlay notes already has the discriminator after a marketing mailer that skipped majority-minority tracts.
• Keep Temporary compensating control in force until manufactured-housing dealer overlay notes is completed after a marketing mailer that skipped majority-minority tracts for CRA strategist.
• Treat manufactured-housing dealer overlay notes as Approve a documented exception because both readings appear after a marketing mailer that skipped majority-minority tracts.
• Refuse a Fair Lending close: CRA strategist does not have the page HMDA data can be relied on turns on in manufactured-housing dealer overlay notes.

Analysis required

• Test a documented exception versus a pattern a mortgage company after a pricing-regression spike 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 CRA and Special-Purpose Programs file, read manufactured-housing dealer overlay notes against a marketing mailer that skipped majority-minority tracts and write the one fact that would move HMDA data can be relied on for CRA strategist.

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 (manufactured-housing dealer overlay notes after a marketing mailer that skipped majority-minority tracts). The follow-on CRA and Special-Purpose Programs action is what CRA strategist does next: implement the option, assign an owner, and log the missing fact.