Fair-lending officer must resolve whether the exam response should concede

Situation

A mortgage company after a pricing-regression spike cannot treat a DOJ or CFPB monitor request for pricing files as color commentary on underwriting exception log by branch. Fair-lending officer must close the exam response should from that extract under Fair Lending / Pricing and Credit Limits.

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 underwriting exception log by branch after a DOJ or CFPB monitor request for pricing files.

Hypotheses to test

• Fair-lending officer can defend Remove access or reverse the item from underwriting exception log by branch after a DOJ or CFPB monitor request for pricing files in a Fair Lending challenge.
• Fair-lending officer cannot defend Remove access or reverse the item from underwriting exception log by branch; Temporary compensating control is what the extract actually supports after a DOJ or CFPB monitor request for pricing files.
• A DOJ or CFPB monitor request for pricing files never reached the population in underwriting exception log by branch — reopen intake, do not close the exam response should.
• Two facts in underwriting exception log by branch after a DOJ or CFPB monitor request for pricing files conflict for fair-lending officer; hold this Pricing and Credit Limits file.

Analysis required

• Flag any disparate-impact table fair-lending officer cannot explain from underwriting exception log by branch.
• Test a documented exception versus a pattern a mortgage company after a pricing-regression spike must defend.
• Match the adverse-action language to the facts in underwriting exception log by branch.
• For this Fair Lending Pricing and Credit Limits file, read underwriting exception log by branch against a DOJ or CFPB monitor request for pricing files 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 (underwriting exception log by branch after a DOJ or CFPB monitor request for pricing files). If underwriting exception log by branch cannot force a Fair Lending label under Pricing and Credit Limits, stop. Do not invent pages a mortgage company after a pricing-regression spike does not have.