Assess whether HMDA data can be relied on for the exam (f7b9a1)

Situation

A manufactured-housing lender with dealer-originated files cannot treat an underwriter chat that used coded language as color commentary on mortgage pricing residual by prohibited-basis group. Exam-response coordinator must close HMDA data can be relied on from that extract under Fair Lending / CRA and Special-Purpose Programs.

Decision

Exam-response coordinator 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 an underwriter chat that used coded language.

Hypotheses to test

• Exam-response coordinator can defend Remove access or reverse the item from mortgage pricing residual by prohibited-basis group after an underwriter chat that used coded language in a Fair Lending challenge.
• Exam-response coordinator 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 an underwriter chat that used coded language.
• An underwriter chat that used coded language 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 an underwriter chat that used coded language conflict for exam-response coordinator; hold this CRA and Special-Purpose Programs file.

Analysis required

• Flag any disparate-impact table exam-response coordinator cannot explain from mortgage pricing residual by prohibited-basis group.
• Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend.
• Match the adverse-action language to the facts in mortgage pricing residual by prohibited-basis group.
• For this Fair Lending CRA and Special-Purpose Programs file, read mortgage pricing residual by prohibited-basis group against an underwriter chat that used coded language and write the one fact that would move HMDA data can be relied on for exam-response coordinator.

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 (mortgage pricing residual by prohibited-basis group after an underwriter chat that used coded language). Lead with the Fair Lending option mortgage pricing residual by prohibited-basis group can support after an underwriter chat that used coded language, then the two facts that force it, then the Monday action for exam-response coordinator in a manufactured-housing lender with dealer-originated files.