Assess whether a redlining pattern exists after controls (a7e353)

Situation

A manufactured-housing lender with dealer-originated files cannot treat a HMDA resubmission that still fails quality edits as color commentary on CRA assessment-area versus lending footprint. Fair-lending officer must close a redlining pattern exists from that extract under Fair Lending / Redlining and HMDA Data.

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 CRA assessment-area versus lending footprint after a HMDA resubmission that still fails quality edits.

Hypotheses to test

• Authorize Remove access or reverse the item now; CRA assessment-area versus lending footprint already has the discriminator after a HMDA resubmission that still fails quality edits.
• Keep Temporary compensating control in force until CRA assessment-area versus lending footprint is completed after a HMDA resubmission that still fails quality edits for fair-lending officer.
• Treat CRA assessment-area versus lending footprint as Approve a documented exception because both readings appear after a HMDA resubmission that still fails quality edits.
• Refuse a Fair Lending close: fair-lending officer does not have the page a redlining pattern exists turns on in CRA assessment-area versus lending footprint.

Analysis required

• Check HMDA coding and underwriting policy against a redlining pattern exists.
• Compare CRA assessment-area versus lending footprint to similarly situated files, second-review notes, and reason codes after a HMDA resubmission that still fails quality edits.
• Flag any disparate-impact table fair-lending officer cannot explain from CRA assessment-area versus lending footprint.
• For this Fair Lending Redlining and HMDA Data file, read CRA assessment-area versus lending footprint against a HMDA resubmission that still fails quality edits and write the one fact that would move a redlining pattern exists 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 (CRA assessment-area versus lending footprint after a HMDA resubmission that still fails quality edits). If CRA assessment-area versus lending footprint cannot force a Fair Lending label under Redlining and HMDA Data, stop. If CRA assessment-area versus lending footprint after a HMDA resubmission that still fails quality edits cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending Redlining and HMDA Data close, fair-lending officer must do not infer a control or scheme beyond the transaction and entitlement evidence.