Assess whether a redlining pattern exists after controls (1d031c)

Situation

Manufactured-housing dealer overlay notes arrived with a branch that stopped taking applications in one ZIP for HMDA data-quality manager. That is a Fair Lending Examination and Notices decision on a redlining pattern exists in a small-business desk using a new vendor score.

Decision

HMDA data-quality manager in a small-business desk using a new vendor score must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using manufactured-housing dealer overlay notes after a branch that stopped taking applications in one ZIP.

Hypotheses to test

• The population in manufactured-housing dealer overlay notes is the one a branch that stopped taking applications in one ZIP named, so Remove access or reverse the item follows for this Examination and Notices file.
• The population in manufactured-housing dealer overlay notes is adjacent only to a branch that stopped taking applications in one ZIP; Temporary compensating control is the honest Fair Lending call.
• A small-business desk using a new vendor score already contained a branch that stopped taking applications in one ZIP before manufactured-housing dealer overlay notes arrived; no new Examination and Notices path.
• Provenance on manufactured-housing dealer overlay notes after a branch that stopped taking applications in one ZIP is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Check HMDA coding and underwriting policy against a redlining pattern exists.
• Compare manufactured-housing dealer overlay notes to similarly situated files, second-review notes, and reason codes after a branch that stopped taking applications in one ZIP.
• Flag any disparate-impact table HMDA data-quality manager cannot explain from manufactured-housing dealer overlay notes.
• For this Fair Lending Examination and Notices file, read manufactured-housing dealer overlay notes against a branch that stopped taking applications in one ZIP and write the one fact that would move a redlining pattern exists 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 / Examination and Notices packet (manufactured-housing dealer overlay notes after a branch that stopped taking applications in one ZIP). The follow-on Examination and Notices action is what HMDA data-quality manager does next: implement the option, assign an owner, and log the missing fact.