Assess whether HMDA data can be relied on for the exam (19370c)

Situation

After a community complaint about appraisal gaps, underwriting exception log by branch is what fair-lending officer can touch in a manufactured-housing lender with dealer-originated files. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this 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 underwriting exception log by branch after a community complaint about appraisal gaps.

Hypotheses to test

• Fair-lending officer can defend Remove access or reverse the item from underwriting exception log by branch after a community complaint about appraisal gaps in a Fair Lending challenge.
• Fair-lending officer cannot defend Remove access or reverse the item from underwriting exception log by branch; Temporary compensating control is what the extract actually supports after a community complaint about appraisal gaps.
• A community complaint about appraisal gaps never reached the population in underwriting exception log by branch — reopen intake, do not close HMDA data can be relied on.
• Two facts in underwriting exception log by branch after a community complaint about appraisal gaps conflict for fair-lending officer; hold this Redlining and HMDA Data file.

Analysis required

• Check HMDA coding and underwriting policy against HMDA data can be relied on.
• Compare underwriting exception log by branch to similarly situated files, second-review notes, and reason codes after a community complaint about appraisal gaps.
• Flag any disparate-impact table fair-lending officer cannot explain from underwriting exception log by branch.
• For this Fair Lending Redlining and HMDA Data file, read underwriting exception log by branch against a community complaint about appraisal gaps and write the one fact that would move HMDA data can be relied on 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 (underwriting exception log by branch after a community complaint about appraisal gaps). Lead with the Fair Lending option underwriting exception log by branch can support after a community complaint about appraisal gaps, then the two facts that force it, then the Monday action for fair-lending officer in a manufactured-housing lender with dealer-originated files.