CRA strategist must resolve whether the exam response should concede a finding

Situation

Small-business decline comparative file set arrived with an underwriter chat that used coded language for CRA strategist. That is a Fair Lending Pricing and Credit Limits decision on the exam response should in a manufactured-housing lender with dealer-originated files.

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 small-business decline comparative file set after an underwriter chat that used coded language.

Hypotheses to test

• An underwriter chat that used coded language is noise around an already-controlled Pricing and Credit Limits process in a manufactured-housing lender with dealer-originated files, given small-business decline comparative file set.
• An underwriter chat that used coded language is the event in small-business decline comparative file set that forces Remove access or reverse the item for CRA strategist under Fair Lending.
• Small-business decline comparative file set shows a one-file miss after an underwriter chat that used coded language, not a Pricing and Credit Limits program failure.
• Small-business decline comparative file set cannot decide the exam response should yet after an underwriter chat that used coded language; hold is the only Fair Lending close a manufactured-housing lender with dealer-originated files can defend.

Analysis required

• Match the adverse-action language to the facts in small-business decline comparative file set.
• Check HMDA coding and underwriting policy against the exam response should.
• Compare small-business decline comparative file set to similarly situated files, second-review notes, and reason codes after an underwriter chat that used coded language.
• For this Fair Lending Pricing and Credit Limits file, read small-business decline comparative file set against an underwriter chat that used coded language and write the one fact that would move the exam response should 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 (small-business decline comparative file set after an underwriter chat that used coded language). If small-business decline comparative file set cannot force a Fair Lending label under Pricing and Credit Limits, stop. If small-business decline comparative file set after an underwriter chat that used coded language cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending Pricing and Credit Limits close, CRA strategist must do not infer a control or scheme beyond the transaction and entitlement evidence.