CRA strategist must resolve whether HMDA data can be relied on for the exam

Situation

Pricing and Credit Limits work in a manufactured-housing lender with dealer-originated files now turns on HMDA data can be relied on because a notice that cites 'other' as the principal reason 40% of the time put underwriting exception log by branch in play. CRA strategist should say what underwriting exception log by branch proves.

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 underwriting exception log by branch after a notice that cites 'other' as the principal reason 40% of the time.

Hypotheses to test

• Authorize Remove access or reverse the item now; underwriting exception log by branch already has the discriminator after a notice that cites 'other' as the principal reason 40% of the time.
• Keep Temporary compensating control in force until underwriting exception log by branch is completed after a notice that cites 'other' as the principal reason 40% of the time for CRA strategist.
• Treat underwriting exception log by branch as Approve a documented exception because both readings appear after a notice that cites 'other' as the principal reason 40% of the time.
• Refuse a Fair Lending close: CRA strategist does not have the page HMDA data can be relied on turns on in underwriting exception log by branch.

Analysis required

• Match the adverse-action language to the facts in underwriting exception log by branch.
• Check HMDA coding and underwriting policy against HMDA data can be relied on.
• Compare underwriting exception log by branch to similarly situated files, second-review notes, and reason codes after a notice that cites 'other' as the principal reason 40% of the time.
• For this Fair Lending Pricing and Credit Limits file, read underwriting exception log by branch against a notice that cites 'other' as the principal reason 40% of the time 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 (underwriting exception log by branch after a notice that cites 'other' as the principal reason 40% of the time). Lead with the Fair Lending option underwriting exception log by branch can support after a notice that cites 'other' as the principal reason 40% of the time, then the two facts that force it, then the Monday action for CRA strategist in a manufactured-housing lender with dealer-originated files.