Assess whether comparative files show second-review bias (3ce544)

Situation

A DOJ or CFPB monitor request for pricing files put small-business decline comparative file set in front of exam-response coordinator in a manufactured-housing lender with dealer-originated files. This Fair Lending / CRA and Special-Purpose Programs close is comparative files show second-review from small-business decline comparative file set, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

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 small-business decline comparative file set after a DOJ or CFPB monitor request for pricing files.

Hypotheses to test

• Authorize Remove access or reverse the item now; small-business decline comparative file set already has the discriminator after a DOJ or CFPB monitor request for pricing files.
• Keep Temporary compensating control in force until small-business decline comparative file set is completed after a DOJ or CFPB monitor request for pricing files for exam-response coordinator.
• Treat small-business decline comparative file set as Approve a documented exception because both readings appear after a DOJ or CFPB monitor request for pricing files.
• Refuse a Fair Lending close: exam-response coordinator does not have the page comparative files show second-review turns on in small-business decline comparative file set.

Analysis required

• Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend.
• Match the adverse-action language to the facts in small-business decline comparative file set.
• Check HMDA coding and underwriting policy against comparative files show second-review.
• For this Fair Lending CRA and Special-Purpose Programs file, read small-business decline comparative file set against a DOJ or CFPB monitor request for pricing files 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 (small-business decline comparative file set after a DOJ or CFPB monitor request for pricing files). The follow-on CRA and Special-Purpose Programs action is what exam-response coordinator does next: implement the option, assign an owner, and log the missing fact.