Assess whether notices match the actual decisioning reasons (b662c3)

SITUATION After a DOJ or CFPB monitor request for pricing files, model-reason-code mapping that does not match notices is what fair-lending officer can touch in a manufactured-housing lender with dealer-originated files. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this Redlining and HMDA Data file.

DECISION Fair-lending officer 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 model-reason-code mapping that does not match notices after a DOJ or CFPB monitor request for pricing files.

HYPOTHESES TO TEST 1. Fair-lending officer can defend Remove access or reverse the item from model-reason-code mapping that does not match notices after a DOJ or CFPB monitor request for pricing files in a Fair Lending challenge. 2. Fair-lending officer cannot defend Remove access or reverse the item from model-reason-code mapping that does not match notices; Temporary compensating control is what the extract actually supports after a DOJ or CFPB monitor request for pricing files. 3. A DOJ or CFPB monitor request for pricing files never reached the population in model-reason-code mapping that does not match notices — reopen intake, do not close notices match the actual. 4. Two facts in model-reason-code mapping that does not match notices after a DOJ or CFPB monitor request for pricing files conflict for fair-lending officer; hold this Redlining and HMDA Data file.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in model-reason-code mapping that does not match notices. 2. Check HMDA coding and underwriting policy against notices match the actual. 3. Compare model-reason-code mapping that does not match notices to similarly situated files, second-review notes, and reason codes after a DOJ or CFPB monitor request for pricing files. 4. For this Fair Lending Redlining and HMDA Data file, read model-reason-code mapping that does not match notices against a DOJ or CFPB monitor request for pricing files and write the one fact that would move notices match the actual for fair-lending officer.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Redlining and HMDA Data packet (model-reason-code mapping that does not match notices after a DOJ or CFPB monitor request for pricing files). Lead with the Fair Lending option model-reason-code mapping that does not match notices can support after a DOJ or CFPB monitor request for pricing files, then the two facts that force it, then the Monday action for fair-lending officer in a manufactured-housing lender with dealer-originated files.