HMDA data-quality manager must resolve whether notices match the actual

Situation

Pricing and Credit Limits work in a lender expanding into majority-minority census tracts now turns on notices match the actual because a notice that cites 'other' as the principal reason 40% of the time put manufactured-housing dealer overlay notes in play. HMDA data-quality manager should say what manufactured-housing dealer overlay notes proves.

Decision

HMDA data-quality manager in a lender expanding into majority-minority census tracts must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using manufactured-housing dealer overlay notes after a notice that cites 'other' as the principal reason 40% of the time.

Hypotheses to test

• Manufactured-housing dealer overlay notes reads as Remove access or reverse the item once a notice that cites 'other' as the principal reason 40% of the time is lined up to the same Fair Lending population.
• Manufactured-housing dealer overlay notes is closer to Temporary compensating control after a notice that cites 'other' as the principal reason 40% of the time; Remove access or reverse the item would over-claim this Pricing and Credit Limits extract.
• Approve a documented exception is still live in manufactured-housing dealer overlay notes for HMDA data-quality manager in a lender expanding into majority-minority census tracts.
• Manufactured-housing dealer overlay notes is missing the fact HMDA data-quality manager needs after a notice that cites 'other' as the principal reason 40% of the time; stop this Fair Lending close.

Analysis required

• Test a documented exception versus a pattern a lender expanding into majority-minority census tracts must defend.
• Match the adverse-action language to the facts in manufactured-housing dealer overlay notes.
• Check HMDA coding and underwriting policy against notices match the actual.
• For this Fair Lending Pricing and Credit Limits file, read manufactured-housing dealer overlay notes against a notice that cites 'other' as the principal reason 40% of the time 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 / Pricing and Credit Limits packet (manufactured-housing dealer overlay notes after a notice that cites 'other' as the principal reason 40% of the time). The follow-on Pricing and Credit Limits action is what HMDA data-quality manager does next: implement the option, assign an owner, and log the missing fact.