HMDA data-quality manager must resolve whether to pause a product pending

Situation

The desk packet is manufactured-housing dealer overlay notes after a DOJ or CFPB monitor request for pricing files. HMDA data-quality manager in a lender expanding into majority-minority census tracts has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending Pricing and Credit Limits file.

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 DOJ or CFPB monitor request for pricing files.

Hypotheses to test

• HMDA data-quality manager can defend Remove access or reverse the item from manufactured-housing dealer overlay notes after a DOJ or CFPB monitor request for pricing files in a Fair Lending challenge.
• 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 a DOJ or CFPB monitor request for pricing files.
• A DOJ or CFPB monitor request for pricing files never reached the population in manufactured-housing dealer overlay notes — reopen intake, do not close to pause a product.
• Two facts in manufactured-housing dealer overlay notes after a DOJ or CFPB monitor request for pricing files conflict for HMDA data-quality manager; hold this Pricing and Credit Limits file.

Analysis required

• 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.
• Match the adverse-action language to the facts in manufactured-housing dealer overlay notes.
• For this Fair Lending Pricing and Credit Limits file, read manufactured-housing dealer overlay notes against a DOJ or CFPB monitor request for pricing files and write the one fact that would move to pause a product 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 DOJ or CFPB monitor request for pricing files). 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.