Assess whether comparative files show second-review bias (76ed5a)

Situation

A manufactured-housing lender with dealer-originated files cannot treat a branch that stopped taking applications in one ZIP as color commentary on credit-card limit assignment disparity table. Community-development lender must close comparative files show second-review from that extract under Fair Lending / Examination and Notices.

Decision

Community-development lender 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 credit-card limit assignment disparity table after a branch that stopped taking applications in one ZIP.

Hypotheses to test

• The population in credit-card limit assignment disparity table is the one a branch that stopped taking applications in one ZIP named, so Remove access or reverse the item follows for this Examination and Notices file.
• The population in credit-card limit assignment disparity table is adjacent only to a branch that stopped taking applications in one ZIP; Temporary compensating control is the honest Fair Lending call.
• A manufactured-housing lender with dealer-originated files already contained a branch that stopped taking applications in one ZIP before credit-card limit assignment disparity table arrived; no new Examination and Notices path.
• Provenance on credit-card limit assignment disparity table after a branch that stopped taking applications in one ZIP is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Match the adverse-action language to the facts in credit-card limit assignment disparity table.
• Check HMDA coding and underwriting policy against comparative files show second-review.
• Compare credit-card limit assignment disparity table to similarly situated files, second-review notes, and reason codes after a branch that stopped taking applications in one ZIP.
• For this Fair Lending Examination and Notices file, read credit-card limit assignment disparity table against a branch that stopped taking applications in one ZIP and write the one fact that would move comparative files show second-review for community-development lender.

Recommendation