Assess whether the exam response should concede a finding (50f564)

SITUATION Exam-response coordinator is responsible for the exam response should in a manufactured-housing lender, using dealer-originated files with SPCP written plan versus actual originations as the only working extract. A notice that cites 'other' as the principal reason 40% of the time is what reset the timeline for this Fair Lending CRA and Special-Purpose Programs file.

DECISION Exam-response coordinator 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 SPCP written plan versus actual originations after a notice that cites 'other' as the principal reason 40% of the time.

HYPOTHESES TO TEST 1. A notice that cites 'other' as the principal reason 40% of the time is noise around an already-controlled CRA and Special-Purpose Programs process in a manufactured-housing lender with dealer-originated files, given SPCP written plan versus actual originations. 2. A notice that cites 'other' as the principal reason 40% of the time is the event in SPCP written plan versus actual originations that forces Remove access or reverse the item for exam-response coordinator under Fair Lending. 3. SPCP written plan versus actual originations shows a one-file miss after a notice that cites 'other' as the principal reason 40% of the time, not a CRA and Special-Purpose Programs program failure. 4. SPCP written plan versus actual originations cannot decide the exam response should yet after a notice that cites 'other' as the principal reason 40% of the time; hold is the only Fair Lending close a manufactured-housing lender with dealer-originated files can defend.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against the exam response should. 2. Compare SPCP written plan versus actual originations to similarly situated files, second-review notes, and reason codes after a notice that cites 'other' as the principal reason 40% of the time. 3. Flag any disparate-impact table exam-response coordinator cannot explain from SPCP written plan versus actual originations. 4. For this Fair Lending CRA and Special-Purpose Programs file, read SPCP written plan versus actual originations against a notice that cites 'other' as the principal reason 40% of the time and write the one fact that would move the exam response should for exam-response coordinator.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / CRA and Special-Purpose Programs packet (SPCP written plan versus actual originations after a notice that cites 'other' as the principal reason 40% of the time). The follow-on CRA and Special-Purpose Programs action is what exam-response coordinator does next: implement the option, assign an owner, and log the missing fact.