Assess whether notices match the actual decisioning reasons (201aa9)

SITUATION HMDA data-quality manager is responsible for notices match the actual in a credit union rolling out a special-purpose credit program, using manufactured-housing dealer overlay notes as the only working extract. An exception rate twice as high for one group after credit controls is what reset the timeline for this Fair Lending CRA and Special-Purpose Programs file.

DECISION HMDA data-quality manager in a credit union rolling out a special-purpose credit program must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using manufactured-housing dealer overlay notes after an exception rate twice as high for one group after credit controls.

HYPOTHESES TO TEST 1. HMDA data-quality manager can defend Remove access or reverse the item from manufactured-housing dealer overlay notes after an exception rate twice as high for one group after credit controls in a Fair Lending challenge. 2. HMDA data-quality manager cannot defend Remove access or reverse the item from manufactured-housing dealer overlay notes; Temporary compensating control is what the extract actually supports after an exception rate twice as high for one group after credit controls. 3. An exception rate twice as high for one group after credit controls never reached the population in manufactured-housing dealer overlay notes — reopen intake, do not close notices match the actual. 4. Two facts in manufactured-housing dealer overlay notes after an exception rate twice as high for one group after credit controls conflict for HMDA data-quality manager; hold this CRA and Special-Purpose Programs file.

ANALYSIS REQUIRED 1. Compare manufactured-housing dealer overlay notes to similarly situated files, second-review notes, and reason codes after an exception rate twice as high for one group after credit controls. 2. Flag any disparate-impact table HMDA data-quality manager cannot explain from manufactured-housing dealer overlay notes. 3. Test a documented exception versus a pattern a credit union rolling out a special-purpose credit program must defend. 4. For this Fair Lending CRA and Special-Purpose Programs file, read manufactured-housing dealer overlay notes against an exception rate twice as high for one group after credit controls and write the one fact that would move notices match the actual 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 / CRA and Special-Purpose Programs packet (manufactured-housing dealer overlay notes after an exception rate twice as high for one group after credit controls). The follow-on CRA and Special-Purpose Programs action is what HMDA data-quality manager does next: implement the option, assign an owner, and log the missing fact.