Assess whether comparative files show second-review bias (19775a)

Situation

A lender expanding into majority-minority census tracts cannot treat a CRA PE that called the assessment area too narrow as color commentary on manufactured-housing dealer overlay notes. Second-review underwriter must close comparative files show second-review from that extract under Fair Lending / CRA and Special-Purpose Programs.

Decision

Second-review underwriter in a lender expanding into majority-minority census tracts must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using manufactured-housing dealer overlay notes after a CRA PE that called the assessment area too narrow.

Hypotheses to test

• Authorize Remove access or reverse the item now; manufactured-housing dealer overlay notes already has the discriminator after a CRA PE that called the assessment area too narrow.
• Keep Temporary compensating control in force until manufactured-housing dealer overlay notes is completed after a CRA PE that called the assessment area too narrow for second-review underwriter.
• Treat manufactured-housing dealer overlay notes as Approve a documented exception because both readings appear after a CRA PE that called the assessment area too narrow.
• Refuse a Fair Lending close: second-review underwriter does not have the page comparative files show second-review turns on in manufactured-housing dealer overlay notes.

Analysis required

• Match the adverse-action language to the facts in manufactured-housing dealer overlay notes.
• Check HMDA coding and underwriting policy against comparative files show second-review.
• Compare manufactured-housing dealer overlay notes 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 manufactured-housing dealer overlay notes 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 second-review underwriter.

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 (manufactured-housing dealer overlay notes after a CRA PE that called the assessment area too narrow). Lead with the Fair Lending option manufactured-housing dealer overlay notes 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 second-review underwriter in a lender expanding into majority-minority census tracts.