Assess whether comparative files show second-review bias (d81f72)

Situation

A manufactured-housing lender with dealer-originated files cannot treat a CRA PE that called the assessment area too narrow as color commentary on HMDA LAR validity and quality edits. Exam-response coordinator must close comparative files show second-review from that extract under Fair Lending / CRA and Special-Purpose Programs.

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 HMDA LAR validity and quality edits after a CRA PE that called the assessment area too narrow.

Hypotheses to test

• Exam-response coordinator can defend Remove access or reverse the item from HMDA LAR validity and quality edits after a CRA PE that called the assessment area too narrow in a Fair Lending challenge.
• Exam-response coordinator cannot defend Remove access or reverse the item from HMDA LAR validity and quality edits; Temporary compensating control is what the extract actually supports after a CRA PE that called the assessment area too narrow.
• A CRA PE that called the assessment area too narrow never reached the population in HMDA LAR validity and quality edits — reopen intake, do not close comparative files show second-review.
• Two facts in HMDA LAR validity and quality edits after a CRA PE that called the assessment area too narrow conflict for exam-response coordinator; hold this CRA and Special-Purpose Programs file.

Analysis required

• Match the adverse-action language to the facts in HMDA LAR validity and quality edits.
• Check HMDA coding and underwriting policy against comparative files show second-review.
• Compare HMDA LAR validity and quality edits to similarly situated files, second-review notes, and reason codes after a CRA PE that called the assessment area too narrow.
• For this Fair Lending CRA and Special-Purpose Programs file, read HMDA LAR validity and quality edits against a CRA PE that called the assessment area too narrow and write the one fact that would move comparative files show second-review for exam-response coordinator.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / CRA and Special-Purpose Programs packet (HMDA LAR validity and quality edits after a CRA PE that called the assessment area too narrow). Lead with the Fair Lending option HMDA LAR validity and quality edits can support after a CRA PE that called the assessment area too narrow, then the two facts that force it, then the Monday action for exam-response coordinator in a manufactured-housing lender with dealer-originated files.