Assess whether the exam response should concede a finding after a SPCP that

SITUATION In a manufactured-housing lender with dealer-originated files, geographic application and origination heat map is the evidence after a SPCP that originated almost no loans to the intended class. CRA strategist has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending Pricing and Credit Limits close using geographic application and origination heat map.

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 geographic application and origination heat map after a SPCP that originated almost no loans to the intended class.

HYPOTHESES TO TEST 1. A manufactured-housing lender with dealer-originated files can accept Remove access or reverse the item on the exam response should only from geographic application and origination heat map after a SPCP that originated almost no loans to the intended class, not from a neighboring Pricing and Credit Limits file. 2. Temporary compensating control is the reading if geographic application and origination heat map after a SPCP that originated almost no loans to the intended class fails the Fair Lending test CRA strategist would cite. 3. Approve a documented exception stays open while geographic application and origination heat map still contains both Remove access or reverse the item and Temporary compensating control signals. 4. Until geographic application and origination heat map after a SPCP that originated almost no loans to the intended class answers the exam response should, CRA strategist should leave the Pricing and Credit Limits close unnamed.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend. 2. Match the adverse-action language to the facts in geographic application and origination heat map. 3. Check HMDA coding and underwriting policy against the exam response should. 4. For this Fair Lending Pricing and Credit Limits file, read geographic application and origination heat map against a SPCP that originated almost no loans to the intended class and write the one fact that would move the exam response should 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 (geographic application and origination heat map after a SPCP that originated almost no loans to the intended class). Lead with the Fair Lending option geographic application and origination heat map can support after a SPCP that originated almost no loans to the intended class, then the two facts that force it, then the Monday action for CRA strategist in a manufactured-housing lender with dealer-originated files.