Whether comparative files show second-review bias from CRA assessment-area

Situation

A manufactured-housing lender with dealer-originated files cannot treat an exception rate twice as high for one group after credit controls as color commentary on CRA assessment-area versus lending footprint. CRA strategist must close comparative files show second-review from that extract under Fair Lending / Pricing and Credit Limits.

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 CRA assessment-area versus lending footprint after an exception rate twice as high for one group after credit controls.

Hypotheses to test

• CRA assessment-area versus lending footprint reads as Remove access or reverse the item once an exception rate twice as high for one group after credit controls is lined up to the same Fair Lending population.
• CRA assessment-area versus lending footprint is closer to Temporary compensating control after an exception rate twice as high for one group after credit controls; Remove access or reverse the item would over-claim this Pricing and Credit Limits extract.
• Approve a documented exception is still live in CRA assessment-area versus lending footprint for CRA strategist in a manufactured-housing lender with dealer-originated files.
• CRA assessment-area versus lending footprint is missing the fact CRA strategist needs after an exception rate twice as high for one group after credit controls; stop this Fair Lending close.

Analysis required

• Match the adverse-action language to the facts in CRA assessment-area versus lending footprint.
• Check HMDA coding and underwriting policy against comparative files show second-review.
• Compare CRA assessment-area versus lending footprint to similarly situated files, second-review notes, and reason codes after an exception rate twice as high for one group after credit controls.
• For this Fair Lending Pricing and Credit Limits file, read CRA assessment-area versus lending footprint against an exception rate twice as high for one group after credit controls and write the one fact that would move comparative files show second-review 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 (CRA assessment-area versus lending footprint after an exception rate twice as high for one group after credit controls). Lead with the Fair Lending option CRA assessment-area versus lending footprint can support after an exception rate twice as high for one group after credit controls, then the two facts that force it, then the Monday action for CRA strategist in a manufactured-housing lender with dealer-originated files.