Whether a redlining pattern exists after controls from model-reason-code

Situation

A redlining pattern exists sits with CRA strategist because a notice that cites 'other' as the principal reason 40% of the time hit a manufactured-housing lender with dealer-originated files. Evidence is model-reason-code mapping that does not match notices; write the Fair Lending Pricing and Credit Limits option that extract can carry.

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 model-reason-code mapping that does not match notices after a notice that cites 'other' as the principal reason 40% of the time.

Hypotheses to test

• The population in model-reason-code mapping that does not match notices is the one a notice that cites 'other' as the principal reason 40% of the time named, so Remove access or reverse the item follows for this Pricing and Credit Limits file.
• The population in model-reason-code mapping that does not match notices is adjacent only to a notice that cites 'other' as the principal reason 40% of the time; Temporary compensating control is the honest Fair Lending call.
• A manufactured-housing lender with dealer-originated files already contained a notice that cites 'other' as the principal reason 40% of the time before model-reason-code mapping that does not match notices arrived; no new Pricing and Credit Limits path.
• Provenance on model-reason-code mapping that does not match notices after a notice that cites 'other' as the principal reason 40% of the time is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• 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 model-reason-code mapping that does not match notices.
• Check HMDA coding and underwriting policy against a redlining pattern exists.
• For this Fair Lending Pricing and Credit Limits file, read model-reason-code mapping that does not match notices against a notice that cites 'other' as the principal reason 40% of the time and write the one fact that would move a redlining pattern exists for CRA strategist.

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