Assess whether the exam response should concede a finding (ef6c63)

SITUATION A CRA PE that called the assessment area too narrow raised whether the exam response should concede a finding for fair-lending officer at a mortgage company after a pricing-regression spike. Manufactured-housing dealer overlay notes is incomplete relative to that question, so Hold remains live until the file is complete.

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 manufactured-housing dealer overlay notes after a CRA PE that called the assessment area too narrow.

HYPOTHESES TO TEST 1. The population in manufactured-housing dealer overlay notes is the one a CRA PE that called the assessment area too narrow named, so Remove access or reverse the item follows for this Pricing and Credit Limits file. 2. The population in manufactured-housing dealer overlay notes is adjacent only to a CRA PE that called the assessment area too narrow; Temporary compensating control is the honest Fair Lending call. 3. A mortgage company after a pricing-regression spike already contained a CRA PE that called the assessment area too narrow before manufactured-housing dealer overlay notes arrived; no new Pricing and Credit Limits path. 4. Provenance on manufactured-housing dealer overlay notes after a CRA PE that called the assessment area too narrow is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

ANALYSIS REQUIRED 1. Flag any disparate-impact table fair-lending officer cannot explain from manufactured-housing dealer overlay notes. 2. Test a documented exception versus a pattern a mortgage company after a pricing-regression spike must defend. 3. Match the adverse-action language to the facts in manufactured-housing dealer overlay notes. 4. For this Fair Lending Pricing and Credit Limits 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 the exam response should 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 (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 fair-lending officer in a mortgage company after a pricing-regression spike.