Assess whether notices match the actual decisioning reasons (ccef82)

SITUATION Geographic application and origination heat map arrived with a CRA PE that called the assessment area too narrow for exam-response coordinator. That is a Fair Lending CRA and Special-Purpose Programs decision on notices match the actual in a manufactured-housing lender with dealer-originated files.

DECISION Exam-response coordinator 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 CRA PE that called the assessment area too narrow.

HYPOTHESES TO TEST 1. The population in geographic application and origination heat map is the one a CRA PE that called the assessment area too narrow named, so Remove access or reverse the item follows for this CRA and Special-Purpose Programs file. 2. The population in geographic application and origination heat map is adjacent only to a CRA PE that called the assessment area too narrow; Temporary compensating control is the honest Fair Lending call. 3. A manufactured-housing lender with dealer-originated files already contained a CRA PE that called the assessment area too narrow before geographic application and origination heat map arrived; no new CRA and Special-Purpose Programs path. 4. Provenance on geographic application and origination heat map after a CRA PE that called the assessment area too narrow is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

ANALYSIS REQUIRED 1. Flag any disparate-impact table exam-response coordinator cannot explain from geographic application and origination heat map. 2. Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend. 3. Match the adverse-action language to the facts in geographic application and origination heat map. 4. For this Fair Lending CRA and Special-Purpose Programs file, read geographic application and origination heat map against a CRA PE that called the assessment area too narrow and write the one fact that would move notices match the actual for exam-response coordinator.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / CRA and Special-Purpose Programs packet (geographic application and origination heat map after a CRA PE that called the assessment area too narrow). Lead with the Fair Lending option geographic application and origination heat map can support after a CRA PE that called the assessment area too narrow, then the two facts that force it, then the Monday action for exam-response coordinator in a manufactured-housing lender with dealer-originated files.