Assess whether the exam response should concede a finding (c4b8a6)

SITUATION After a board asking if the bank should settle a matched-pair study, mortgage pricing residual by prohibited-basis group is what community-development lender 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 Examination and Notices file.

DECISION Community-development lender 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 mortgage pricing residual by prohibited-basis group after a board asking if the bank should settle a matched-pair study.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; mortgage pricing residual by prohibited-basis group already has the discriminator after a board asking if the bank should settle a matched-pair study. 2. Keep Temporary compensating control in force until mortgage pricing residual by prohibited-basis group is completed after a board asking if the bank should settle a matched-pair study for community-development lender. 3. Treat mortgage pricing residual by prohibited-basis group as Approve a documented exception because both readings appear after a board asking if the bank should settle a matched-pair study. 4. Refuse a Fair Lending close: community-development lender does not have the decision the exam response should turns on in mortgage pricing residual by prohibited-basis group.

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 mortgage pricing residual by prohibited-basis group. 3. Check HMDA coding and underwriting policy against the exam response should. 4. For this Fair Lending Examination and Notices file, read mortgage pricing residual by prohibited-basis group against a board asking if the bank should settle a matched-pair study and write the one fact that would move the exam response should for community-development lender.

RECOMMENDATION Community-development lender should take Temporary compensating control on the exam response should unless mortgage pricing residual by prohibited-basis group after a board asking if the bank should settle a matched-pair study already proves Remove access or reverse the item for this Examination and Notices packet in a manufactured-housing lender with dealer-originated files. Keep Approve a documented exception live only while mortgage pricing residual by prohibited-basis group is missing the decision the exam response should turns on. The working test on mortgage pricing residual by prohibited-basis group is whether Test a documented exception versus a pattern a manufactured-housing lender with dealer-ori.