Exam-response coordinator must resolve whether a model update needs

Situation

After a SPCP that originated almost no loans to the intended class, manufactured-housing dealer overlay notes is what exam-response coordinator can touch in an institution preparing for a redlining exam. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this Pricing and Credit Limits file.

Decision

Exam-response coordinator in an institution preparing for a redlining exam must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using manufactured-housing dealer overlay notes after a SPCP that originated almost no loans to the intended class.

Hypotheses to test

• The population in manufactured-housing dealer overlay notes is the one a SPCP that originated almost no loans to the intended class named, so Remove access or reverse the item follows for this Pricing and Credit Limits file.
• The population in manufactured-housing dealer overlay notes is adjacent only to a SPCP that originated almost no loans to the intended class; Temporary compensating control is the honest Fair Lending call.
• An institution preparing for a redlining exam already contained a SPCP that originated almost no loans to the intended class before manufactured-housing dealer overlay notes arrived; no new Pricing and Credit Limits path.
• Provenance on manufactured-housing dealer overlay notes after a SPCP that originated almost no loans to the intended class is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Match the adverse-action language to the facts in manufactured-housing dealer overlay notes.
• Check HMDA coding and underwriting policy against a model update needs.
• Compare manufactured-housing dealer overlay notes to similarly situated files, second-review notes, and reason codes after a SPCP that originated almost no loans to the intended class.
• For this Fair Lending Pricing and Credit Limits file, read manufactured-housing dealer overlay notes against a SPCP that originated almost no loans to the intended class and write the one fact that would move a model update needs for exam-response coordinator.

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 (manufactured-housing dealer overlay notes after a SPCP that originated almost no loans to the intended class). If manufactured-housing dealer overlay notes cannot force a Fair Lending label under Pricing and Credit Limits, stop. Do not invent pages an institution preparing for a redlining exam does not have.