Comparative Files Show Second-review Bias — CRA Strategist

Situation

Comparative files show second-review sits with CRA strategist because a CRA PE that called the assessment area too narrow hit a manufactured-housing lender with dealer-originated files. Evidence is model-reason-code mapping that does not match notices; write the Fair Lending Pricing and Credit Limits option that extract can carry.

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 model-reason-code mapping that does not match notices after a CRA PE that called the assessment area too narrow.

Hypotheses to test

• Authorize Remove access or reverse the item now; model-reason-code mapping that does not match notices already has the discriminator after a CRA PE that called the assessment area too narrow.
• Keep Temporary compensating control in force until model-reason-code mapping that does not match notices is completed after a CRA PE that called the assessment area too narrow for CRA strategist.
• Treat model-reason-code mapping that does not match notices 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: CRA strategist does not have the page comparative files show second-review turns on in model-reason-code mapping that does not match notices.

Analysis required

• Compare model-reason-code mapping that does not match notices to similarly situated files, second-review notes, and reason codes after a CRA PE that called the assessment area too narrow.
• Flag any disparate-impact table CRA strategist cannot explain from model-reason-code mapping that does not match notices.
• Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend.
• For this Fair Lending Pricing and Credit Limits file, read model-reason-code mapping that does not match notices 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 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 (model-reason-code mapping that does not match notices after a CRA PE that called the assessment area too narrow). Lead with the Fair Lending option model-reason-code mapping that does not match notices 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 CRA strategist in a manufactured-housing lender with dealer-originated files.