Assess whether HMDA data can be relied on for the exam (cfb4f6)

Situation

A DOJ or CFPB monitor request for pricing files put mortgage pricing residual by prohibited-basis group in front of community-development lender in a manufactured-housing lender with dealer-originated files. This Fair Lending / Examination and Notices close is HMDA data can be relied on from mortgage pricing residual by prohibited-basis group, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

Decision

Community-development lender 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 mortgage pricing residual by prohibited-basis group after a DOJ or CFPB monitor request for pricing files.

Hypotheses to test

• Community-development lender can defend Remove access or reverse the item from mortgage pricing residual by prohibited-basis group after a DOJ or CFPB monitor request for pricing files in a Fair Lending challenge.
• Community-development lender cannot defend Remove access or reverse the item from mortgage pricing residual by prohibited-basis group; Temporary compensating control is what the extract actually supports after a DOJ or CFPB monitor request for pricing files.
• A DOJ or CFPB monitor request for pricing files never reached the population in mortgage pricing residual by prohibited-basis group — reopen intake, do not close HMDA data can be relied on.
• Two facts in mortgage pricing residual by prohibited-basis group after a DOJ or CFPB monitor request for pricing files conflict for community-development lender; hold this Examination and Notices file.

Analysis required

• Match the adverse-action language to the facts in mortgage pricing residual by prohibited-basis group.
• Check HMDA coding and underwriting policy against HMDA data can be relied on.
• Compare mortgage pricing residual by prohibited-basis group to similarly situated files, second-review notes, and reason codes after a DOJ or CFPB monitor request for pricing files.
• For this Fair Lending Examination and Notices file, read mortgage pricing residual by prohibited-basis group 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 community-development lender.