Assess whether notices match the actual decisioning reasons (adc185)

SITUATION In a manufactured-housing lender with dealer-originated files, CRA assessment-area versus lending footprint is the evidence after a SPCP that originated almost no loans to the intended class. Community-development lender has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending Examination and Notices close using CRA assessment-area versus lending footprint.

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 CRA assessment-area versus lending footprint after a SPCP that originated almost no loans to the intended class.

HYPOTHESES TO TEST 1. CRA assessment-area versus lending footprint reads as Remove access or reverse the item once a SPCP that originated almost no loans to the intended class is lined up to the same Fair Lending population. 2. CRA assessment-area versus lending footprint is closer to Temporary compensating control after a SPCP that originated almost no loans to the intended class; Remove access or reverse the item would over-claim this Examination and Notices extract. 3. Approve a documented exception is still live in CRA assessment-area versus lending footprint for community-development lender in a manufactured-housing lender with dealer-originated files. 4. CRA assessment-area versus lending footprint is missing the fact community-development lender needs after a SPCP that originated almost no loans to the intended class; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Flag any disparate-impact table community-development lender cannot explain from CRA assessment-area versus lending footprint. 2. Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend. 3. Match the adverse-action language to the facts in CRA assessment-area versus lending footprint. 4. For this Fair Lending Examination and Notices file, read CRA assessment-area versus lending footprint against a SPCP that originated almost no loans to the intended class and write the one fact that would move notices match the actual for community-development lender.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Examination and Notices packet (CRA assessment-area versus lending footprint after a SPCP that originated almost no loans to the intended class). The follow-on Examination and Notices action is what community-development lender does next: implement the option, assign an owner, and log the missing fact.