Notices Match the Actual Decisioning Reasons

Situation

Pricing and Credit Limits work in a manufactured-housing lender with dealer-originated files now turns on notices match the actual because a CRA PE that called the assessment area too narrow put HMDA LAR validity and quality edits in play. CRA strategist should say what HMDA LAR validity and quality edits proves.

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 HMDA LAR validity and quality edits after a CRA PE that called the assessment area too narrow.

Hypotheses to test

• The population in HMDA LAR validity and quality edits 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.
• The population in HMDA LAR validity and quality edits is adjacent only to a CRA PE that called the assessment area too narrow; Temporary compensating control is the honest Fair Lending call.
• A manufactured-housing lender with dealer-originated files already contained a CRA PE that called the assessment area too narrow before HMDA LAR validity and quality edits arrived; no new Pricing and Credit Limits path.
• Provenance on HMDA LAR validity and quality edits 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

• Compare HMDA LAR validity and quality edits 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 HMDA LAR validity and quality edits.
• 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 HMDA LAR validity and quality edits against a CRA PE that called the assessment area too narrow and write the one fact that would move notices match the actual 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 (HMDA LAR validity and quality edits after a CRA PE that called the assessment area too narrow). Lead with the Fair Lending option HMDA LAR validity and quality edits 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.