Assess whether notices match the actual decisioning reasons from mortgage

SITUATION In a bank with thin HMDA LAR quality, mortgage pricing residual by prohibited-basis group is the evidence after a DOJ or CFPB monitor request for pricing files. Community-development lender has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending Pricing and Credit Limits close using mortgage pricing residual by prohibited-basis group.

DECISION Community-development lender in a bank with thin HMDA LAR quality must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using mortgage pricing residual by prohibited-basis group after a DOJ or CFPB monitor request for pricing files.

HYPOTHESES TO TEST 1. The population in mortgage pricing residual by prohibited-basis group is the one a DOJ or CFPB monitor request for pricing files named, so Remove access or reverse the item follows for this Pricing and Credit Limits file. 2. The population in mortgage pricing residual by prohibited-basis group is adjacent only to a DOJ or CFPB monitor request for pricing files; Temporary compensating control is the honest Fair Lending call. 3. A bank with thin HMDA LAR quality already contained a DOJ or CFPB monitor request for pricing files before mortgage pricing residual by prohibited-basis group arrived; no new Pricing and Credit Limits path. 4. Provenance on mortgage pricing residual by prohibited-basis group after a DOJ or CFPB monitor request for pricing files is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against notices match the actual. 2. Compare mortgage pricing residual by prohibited-basis group to similarly situated files, second-review notes, and reason codes after a DOJ or CFPB monitor request for pricing files. 3. Flag any disparate-impact table community-development lender cannot explain from mortgage pricing residual by prohibited-basis group. 4. For this Fair Lending Pricing and Credit Limits file, read mortgage pricing residual by prohibited-basis group against a DOJ or CFPB monitor request for pricing files and write the one fact that would move notices match the actual for community-development lender.

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 (mortgage pricing residual by prohibited-basis group after a DOJ or CFPB monitor request for pricing files). Lead with the Fair Lending option mortgage pricing residual by prohibited-basis group can support after a DOJ or CFPB monitor request for pricing files, then the two facts that force it, then the Monday action for community-development lender in a bank with thin HMDA LAR quality.