Assess whether HMDA data can be relied on for the exam after a DOJ or CFPB

Situation

A manufactured-housing lender with dealer-originated files cannot treat a DOJ or CFPB monitor request for pricing files as color commentary on SPCP written plan versus actual originations. CRA strategist must close HMDA data can be relied on from that extract under Fair Lending / Pricing and Credit Limits.

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 SPCP written plan versus actual originations after a DOJ or CFPB monitor request for pricing files.

Hypotheses to test

• A DOJ or CFPB monitor request for pricing files is noise around an already-controlled Pricing and Credit Limits process in a manufactured-housing lender with dealer-originated files, given SPCP written plan versus actual originations.
• A DOJ or CFPB monitor request for pricing files is the event in SPCP written plan versus actual originations that forces Remove access or reverse the item for CRA strategist under Fair Lending.
• SPCP written plan versus actual originations shows a one-file miss after a DOJ or CFPB monitor request for pricing files, not a Pricing and Credit Limits program failure.
• SPCP written plan versus actual originations cannot decide HMDA data can be relied on 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

• Flag any disparate-impact table CRA strategist cannot explain from SPCP written plan versus actual originations.
• 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.
• For this Fair Lending Pricing and Credit Limits file, read SPCP written plan versus actual originations against a DOJ or CFPB monitor request for pricing files and write the one fact that would move HMDA data can be relied on 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 (SPCP written plan versus actual originations after a DOJ or CFPB monitor request for pricing files). Lead with the Fair Lending option SPCP written plan versus actual originations can support after a DOJ or CFPB monitor request for pricing files, then the two facts that force it, then the Monday action for CRA strategist in a manufactured-housing lender with dealer-originated files.