Assess whether a redlining pattern exists after controls (f6076e)

Situation

Community-development lender owns a redlining pattern exists inside a manufactured-housing lender with dealer-originated files with SPCP written plan versus actual originations as the only packet. A notice that cites 'other' as the principal reason 40% of the time is what changed the clock for this Fair Lending 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 SPCP written plan versus actual originations after a notice that cites 'other' as the principal reason 40% of the time.

Hypotheses to test

• SPCP written plan versus actual originations reads as Remove access or reverse the item once a notice that cites 'other' as the principal reason 40% of the time is lined up to the same Fair Lending population.
• SPCP written plan versus actual originations is closer to Temporary compensating control after a notice that cites 'other' as the principal reason 40% of the time; Remove access or reverse the item would over-claim this Examination and Notices extract.
• Approve a documented exception is still live in SPCP written plan versus actual originations for community-development lender in a manufactured-housing lender with dealer-originated files.
• SPCP written plan versus actual originations is missing the fact community-development lender needs after a notice that cites 'other' as the principal reason 40% of the time; stop this Fair Lending close.

Analysis required

• Match the adverse-action language to the facts in SPCP written plan versus actual originations.
• Check HMDA coding and underwriting policy against a redlining pattern exists.
• 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.
• For this Fair Lending Examination and Notices 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 a redlining pattern exists for community-development lender.

Recommendation