Assess whether comparative files show second-review bias (a6141b)

Situation

After a HMDA resubmission that still fails quality edits, SPCP written plan versus actual originations is what exam-response coordinator 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 CRA and Special-Purpose Programs file.

Decision

Exam-response coordinator 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 SPCP written plan versus actual originations after a HMDA resubmission that still fails quality edits.

Hypotheses to test

• Authorize Remove access or reverse the item now; SPCP written plan versus actual originations already has the discriminator after a HMDA resubmission that still fails quality edits.
• Keep Temporary compensating control in force until SPCP written plan versus actual originations is completed after a HMDA resubmission that still fails quality edits for exam-response coordinator.
• Treat SPCP written plan versus actual originations as Approve a documented exception because both readings appear after a HMDA resubmission that still fails quality edits.
• Refuse a Fair Lending close: exam-response coordinator does not have the page comparative files show second-review turns on in SPCP written plan versus actual originations.

Analysis required

• Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend.
• Match the adverse-action language to the facts in SPCP written plan versus actual originations.
• Check HMDA coding and underwriting policy against comparative files show second-review.
• For this Fair Lending CRA and Special-Purpose Programs file, read SPCP written plan versus actual originations against a HMDA resubmission that still fails quality edits and write the one fact that would move comparative files show second-review for exam-response coordinator.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / CRA and Special-Purpose Programs packet (SPCP written plan versus actual originations after a HMDA resubmission that still fails quality edits). Lead with the Fair Lending option SPCP written plan versus actual originations can support after a HMDA resubmission that still fails quality edits, then the two facts that force it, then the Monday action for exam-response coordinator in a manufactured-housing lender with dealer-originated files.