Fair-lending officer must resolve whether comparative files show

Situation

After a DOJ or CFPB monitor request for pricing files, HMDA LAR validity and quality edits is what fair-lending officer can touch in a mortgage company after a pricing-regression spike. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this Pricing and Credit Limits file.

Decision

Fair-lending officer in a mortgage company after a pricing-regression spike 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 DOJ or CFPB monitor request for pricing files.

Hypotheses to test

• A DOJ or CFPB monitor request for pricing files is noise around an already-controlled Pricing and Credit Limits process in a mortgage company after a pricing-regression spike, given HMDA LAR validity and quality edits.
• A DOJ or CFPB monitor request for pricing files is the event in HMDA LAR validity and quality edits that forces Remove access or reverse the item for fair-lending officer under Fair Lending.
• HMDA LAR validity and quality edits shows a one-file miss after a DOJ or CFPB monitor request for pricing files, not a Pricing and Credit Limits program failure.
• HMDA LAR validity and quality edits cannot decide comparative files show second-review yet after a DOJ or CFPB monitor request for pricing files; hold is the only Fair Lending close a mortgage company after a pricing-regression spike can defend.

Analysis required

• Test a documented exception versus a pattern a mortgage company after a pricing-regression spike must defend.
• 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.
• For this Fair Lending Pricing and Credit Limits file, read HMDA LAR validity and quality edits against a DOJ or CFPB monitor request for pricing files and write the one fact that would move comparative files show second-review for fair-lending officer.

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 (HMDA LAR validity and quality edits after a DOJ or CFPB monitor request for pricing files). If HMDA LAR validity and quality edits cannot force a Fair Lending label under Pricing and Credit Limits, stop. Do not invent pages a mortgage company after a pricing-regression spike does not have.