Assess whether the exam response should concede a finding (12d95f)

SITUATION In a manufactured-housing lender with dealer-originated files, geographic application and origination heat map is the evidence after a DOJ or CFPB monitor request for pricing files. Community-development lender has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending Examination and Notices close using geographic application and origination heat map.

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 geographic application and origination heat map after a DOJ or CFPB monitor request for pricing files.

HYPOTHESES TO TEST 1. The population in geographic application and origination heat map is the one a DOJ or CFPB monitor request for pricing files named, so Remove access or reverse the item follows for this Examination and Notices file. 2. The population in geographic application and origination heat map is adjacent only to a DOJ or CFPB monitor request for pricing files; Temporary compensating control is the honest Fair Lending call. 3. A manufactured-housing lender with dealer-originated files already contained a DOJ or CFPB monitor request for pricing files before geographic application and origination heat map arrived; no new Examination and Notices path. 4. Provenance on geographic application and origination heat map after a DOJ or CFPB monitor request for pricing files is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against the exam response should. 2. Compare geographic application and origination heat map to similarly situated files, second-review notes, and reason codes after a DOJ or CFPB monitor request for pricing files. 3. Flag any disparate-impact table community-development lender cannot explain from geographic application and origination heat map. 4. For this Fair Lending Examination and Notices file, read geographic application and origination heat map against a DOJ or CFPB monitor request for pricing files and write the one fact that would move the exam response should for community-development lender.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Examination and Notices packet (geographic application and origination heat map after a DOJ or CFPB monitor request for pricing files). The follow-on Examination and Notices action is what community-development lender does next: implement the option, assign an owner, and log the missing fact.