Whether a redlining pattern exists after controls from manufactured-housing

Situation

A SPCP that originated almost no loans to the intended class put manufactured-housing dealer overlay notes in front of HMDA data-quality manager in a lender expanding into majority-minority census tracts. This Fair Lending / Pricing and Credit Limits close is a redlining pattern exists from manufactured-housing dealer overlay notes, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

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 SPCP that originated almost no loans to the intended class.

Hypotheses to test

• A SPCP that originated almost no loans to the intended class is noise around an already-controlled Pricing and Credit Limits process in a lender expanding into majority-minority census tracts, given manufactured-housing dealer overlay notes.
• A SPCP that originated almost no loans to the intended class is the event in manufactured-housing dealer overlay notes that forces Remove access or reverse the item for HMDA data-quality manager under Fair Lending.
• Manufactured-housing dealer overlay notes shows a one-file miss after a SPCP that originated almost no loans to the intended class, not a Pricing and Credit Limits program failure.
• Manufactured-housing dealer overlay notes cannot decide a redlining pattern exists yet after a SPCP that originated almost no loans to the intended class; hold is the only Fair Lending close a lender expanding into majority-minority census tracts can defend.

Analysis required

• Compare manufactured-housing dealer overlay notes to similarly situated files, second-review notes, and reason codes after a SPCP that originated almost no loans to the intended class.
• Flag any disparate-impact table HMDA data-quality manager cannot explain from manufactured-housing dealer overlay notes.
• Test a documented exception versus a pattern a lender expanding into majority-minority census tracts must defend.
• For this Fair Lending Pricing and Credit Limits file, read manufactured-housing dealer overlay notes against a SPCP that originated almost no loans to the intended class and write the one fact that would move a redlining pattern exists for HMDA data-quality manager.