HMDA data-quality manager must resolve whether the CRA plan is strategy

Situation

Mortgage pricing residual by prohibited-basis group arrived with a DOJ or CFPB monitor request for pricing files for HMDA data-quality manager. That is a Fair Lending Pricing and Credit Limits decision on the CRA plan is in a lender expanding into majority-minority census tracts.

Decision

HMDA data-quality manager in a lender expanding into majority-minority census tracts must choose The CRA plan is strategy / Window dressing using mortgage pricing residual by prohibited-basis group after a DOJ or CFPB monitor request for pricing files.

Hypotheses to test

• Mortgage pricing residual by prohibited-basis group reads as The CRA plan is strategy once a DOJ or CFPB monitor request for pricing files is lined up to the same Fair Lending population.
• Mortgage pricing residual by prohibited-basis group is closer to Window dressing after a DOJ or CFPB monitor request for pricing files; The CRA plan is strategy would over-claim this Pricing and Credit Limits extract.
• A dual reading is still live in mortgage pricing residual by prohibited-basis group for HMDA data-quality manager in a lender expanding into majority-minority census tracts.
• Mortgage pricing residual by prohibited-basis group is missing the fact HMDA data-quality manager needs after a DOJ or CFPB monitor request for pricing files; stop this Fair Lending close.

Analysis required

• Match the adverse-action language to the facts in mortgage pricing residual by prohibited-basis group.
• Check HMDA coding and underwriting policy against the CRA plan is.
• Compare mortgage pricing residual by prohibited-basis group to similarly situated files, second-review notes, and reason codes after a DOJ or CFPB monitor request for pricing files.
• For this Fair Lending Pricing and Credit Limits file, read mortgage pricing residual by prohibited-basis group against a DOJ or CFPB monitor request for pricing files and write the one fact that would move the CRA plan is for HMDA data-quality manager.

Recommendation

Choose The CRA plan is strategy / Window dressing on this Fair Lending / Pricing and Credit Limits packet (mortgage pricing residual by prohibited-basis group after a DOJ or CFPB monitor request for pricing files). If mortgage pricing residual by prohibited-basis group cannot force a Fair Lending label under Pricing and Credit Limits, stop. If mortgage pricing residual by prohibited-basis group after a DOJ or CFPB monitor request for pricing files cannot support The CRA plan is strategy versus Window dressing on this Fair Lending Pricing and Credit Limits close, HMDA data-quality manager must do not infer a control or scheme beyond the transaction and entitlement evidence.