Assess whether comparative files show second-review bias (ba44b5)

Situation

After a DOJ or CFPB monitor request for pricing files, mortgage pricing residual by prohibited-basis group is what fair-lending officer can touch in a manufactured-housing lender with dealer-originated files. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this Redlining and HMDA Data file.

Decision

Fair-lending officer 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 mortgage pricing residual by prohibited-basis group 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 mortgage pricing residual by prohibited-basis group 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 mortgage pricing residual by prohibited-basis group; 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 mortgage pricing residual by prohibited-basis group — reopen intake, do not close comparative files show second-review.
• Two facts in mortgage pricing residual by prohibited-basis group after a DOJ or CFPB monitor request for pricing files conflict for fair-lending officer; hold this Redlining and HMDA Data file.

Analysis required

• Match the adverse-action language to the facts in mortgage pricing residual by prohibited-basis group.
• Check HMDA coding and underwriting policy against comparative files show second-review.
• 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.
• For this Fair Lending Redlining and HMDA Data 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 comparative files show second-review for fair-lending officer.

Recommendation