CRA strategist must resolve whether notices match the actual decisioning

Situation

A manufactured-housing lender with dealer-originated files cannot treat an underwriter chat that used coded language as color commentary on small-business decline comparative file set. CRA strategist must close notices match the actual 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 small-business decline comparative file set after an underwriter chat that used coded language.

Hypotheses to test

• Authorize Remove access or reverse the item now; small-business decline comparative file set already has the discriminator after an underwriter chat that used coded language.
• Keep Temporary compensating control in force until small-business decline comparative file set is completed after an underwriter chat that used coded language for CRA strategist.
• Treat small-business decline comparative file set as Approve a documented exception because both readings appear after an underwriter chat that used coded language.
• Refuse a Fair Lending close: CRA strategist does not have the page notices match the actual turns on in small-business decline comparative file set.

Analysis required

• Check HMDA coding and underwriting policy against notices match the actual.
• 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.
• Flag any disparate-impact table CRA strategist cannot explain from small-business decline comparative file set.
• 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 notices match the actual 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). Lead with the Fair Lending option small-business decline comparative file set can support after an underwriter chat that used coded language, then the two facts that force it, then the Monday action for CRA strategist in a manufactured-housing lender with dealer-originated files.