Assess whether line assignments have a disparate impact the bank will defend

SITUATION Mortgage pricing residual by prohibited-basis group arrived with a CRA PE that called the assessment area too narrow for exam-response coordinator. That is a Fair Lending CRA and Special-Purpose Programs decision on line assignments have a in a manufactured-housing lender with dealer-originated files.

DECISION Exam-response coordinator 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 mortgage pricing residual by prohibited-basis group after a CRA PE that called the assessment area too narrow.

HYPOTHESES TO TEST 1. A CRA PE that called the assessment area too narrow is noise around an already-controlled CRA and Special-Purpose Programs process in a manufactured-housing lender with dealer-originated files, given mortgage pricing residual by prohibited-basis group. 2. A CRA PE that called the assessment area too narrow is the event in mortgage pricing residual by prohibited-basis group that forces Remove access or reverse the item for exam-response coordinator under Fair Lending. 3. Mortgage pricing residual by prohibited-basis group shows a one-file miss after a CRA PE that called the assessment area too narrow, not a CRA and Special-Purpose Programs program failure. 4. Mortgage pricing residual by prohibited-basis group cannot decide line assignments have a yet after a CRA PE that called the assessment area too narrow; hold is the only Fair Lending close a manufactured-housing lender with dealer-originated files can defend.

ANALYSIS REQUIRED 1. Flag any disparate-impact table exam-response coordinator cannot explain from mortgage pricing residual by prohibited-basis group. 2. Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend. 3. Match the adverse-action language to the facts in mortgage pricing residual by prohibited-basis group. 4. For this Fair Lending CRA and Special-Purpose Programs file, read mortgage pricing residual by prohibited-basis group against a CRA PE that called the assessment area too narrow and write the one fact that would move line assignments have a for exam-response coordinator.

RECOMMENDATION A manufactured-housing lender with dealer-originated files needs a named owner on line assignments have a. Assign exam-response coordinator to execute Remove access or reverse the item when mortgage pricing residual by prohibited-basis group after a CRA PE that called the assessment area too narrow is complete, or Temporary compensating control when the CRA and Special-Purpose Programs packet still lacks the discriminator in mortgage pricing residual by prohibited-basis group.