Assess whether comparative files show second-review bias (95868f)

Situation

Exam-response coordinator in a manufactured-housing lender with dealer-originated files has one working extract — SPCP written plan versus actual originations — after a branch that stopped taking applications in one ZIP. If SPCP written plan versus actual originations cannot support comparative files show second-review, the honest Fair Lending output is hold.

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 SPCP written plan versus actual originations after a branch that stopped taking applications in one ZIP.

Hypotheses to test

• The population in SPCP written plan versus actual originations is the one a branch that stopped taking applications in one ZIP named, so Remove access or reverse the item follows for this CRA and Special-Purpose Programs file.
• The population in SPCP written plan versus actual originations is adjacent only to a branch that stopped taking applications in one ZIP; Temporary compensating control is the honest Fair Lending call.
• A manufactured-housing lender with dealer-originated files already contained a branch that stopped taking applications in one ZIP before SPCP written plan versus actual originations arrived; no new CRA and Special-Purpose Programs path.
• Provenance on SPCP written plan versus actual originations after a branch that stopped taking applications in one ZIP is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

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 SPCP written plan versus actual originations.
• Check HMDA coding and underwriting policy against comparative files show second-review.
• For this Fair Lending CRA and Special-Purpose Programs file, read SPCP written plan versus actual originations against a branch that stopped taking applications in one ZIP 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 (SPCP written plan versus actual originations after a branch that stopped taking applications in one ZIP). 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.