Assess whether the exam response should concede a finding (57b036)

SITUATION A manufactured-housing lender with dealer-originated files cannot treat a DOJ or CFPB monitor request for pricing files as incidental context on appraisal-gap outcomes in majority-minority tracts. Fair-lending officer must close the exam response should from that extract under Fair Lending / Redlining and HMDA Data.

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 appraisal-gap outcomes in majority-minority tracts after a DOJ or CFPB monitor request for pricing files.

HYPOTHESES TO TEST 1. A DOJ or CFPB monitor request for pricing files is noise around an already-controlled Redlining and HMDA Data process in a manufactured-housing lender with dealer-originated files, given appraisal-gap outcomes in majority-minority tracts. 2. A DOJ or CFPB monitor request for pricing files is the event in appraisal-gap outcomes in majority-minority tracts that forces Remove access or reverse the item for fair-lending officer under Fair Lending. 3. Appraisal-gap outcomes in majority-minority tracts shows a one-file miss after a DOJ or CFPB monitor request for pricing files, not a Redlining and HMDA Data program failure. 4. Appraisal-gap outcomes in majority-minority tracts cannot decide the exam response should yet after a DOJ or CFPB monitor request for pricing files; hold is the only Fair Lending close a manufactured-housing lender with dealer-originated files can defend.

ANALYSIS REQUIRED 1. Compare appraisal-gap outcomes in majority-minority tracts to similarly situated files, second-review notes, and reason codes after a DOJ or CFPB monitor request for pricing files. 2. Flag any disparate-impact table fair-lending officer cannot explain from appraisal-gap outcomes in majority-minority tracts. 3. Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend. 4. For this Fair Lending Redlining and HMDA Data file, read appraisal-gap outcomes in majority-minority tracts against a DOJ or CFPB monitor request for pricing files and write the one fact that would move the exam response should for fair-lending officer.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Redlining and HMDA Data packet (appraisal-gap outcomes in majority-minority tracts after a DOJ or CFPB monitor request for pricing files). Lead with the Fair Lending option appraisal-gap outcomes in majority-minority tracts can support after a DOJ or CFPB monitor request for pricing files, then the two facts that force it, then the Monday action for fair-lending officer in a manufactured-housing lender with dealer-originated files.