Assess whether comparative files show second-review bias from geographic

SITUATION Pricing and Credit Limits work in a manufactured-housing lender with dealer-originated files now turns on comparative files show second-review because a vendor score change with no disparate-impact test put geographic application and origination heat map in play. CRA strategist should say what geographic application and origination heat map proves.

DECISION CRA strategist 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 geographic application and origination heat map after a vendor score change with no disparate-impact test.

HYPOTHESES TO TEST 1. A vendor score change with no disparate-impact test is noise around an already-controlled Pricing and Credit Limits process in a manufactured-housing lender with dealer-originated files, given geographic application and origination heat map. 2. A vendor score change with no disparate-impact test is the event in geographic application and origination heat map that forces Remove access or reverse the item for CRA strategist under Fair Lending. 3. Geographic application and origination heat map shows a one-file miss after a vendor score change with no disparate-impact test, not a Pricing and Credit Limits program failure. 4. Geographic application and origination heat map cannot decide comparative files show second-review yet after a vendor score change with no disparate-impact test; hold is the only Fair Lending close a manufactured-housing lender with dealer-originated files can defend.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in geographic application and origination heat map. 2. Check HMDA coding and underwriting policy against comparative files show second-review. 3. Compare geographic application and origination heat map to similarly situated files, second-review notes, and reason codes after a vendor score change with no disparate-impact test. 4. For this Fair Lending Pricing and Credit Limits file, read geographic application and origination heat map against a vendor score change with no disparate-impact test and write the one fact that would move comparative files show second-review for CRA strategist.

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 (geographic application and origination heat map after a vendor score change with no disparate-impact test). Lead with the Fair Lending option geographic application and origination heat map can support after a vendor score change with no disparate-impact test, then the two facts that force it, then the Monday action for CRA strategist in a manufactured-housing lender with dealer-originated files.