Assess whether to pause a product pending a lookback (76cd3f)

SITUATION Exam-response coordinator in a manufactured-housing lender with dealer-originated files has one working extract — adverse-action notice principal-reason sample — after a SPCP that originated almost no loans to the intended class. Exam-response coordinator in a manufactured-housing lender with dealer-originated files has adverse-action notice principal-reason sample after a SPCP that originated almost no loans to the intended class. If that extract cannot support to pause a product, the only defensible Fair Lending CRA and Special-Purpose Programs output is hold.

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 adverse-action notice principal-reason sample after a SPCP that originated almost no loans to the intended class.

HYPOTHESES TO TEST 1. Exam-response coordinator can defend Remove access or reverse the item from adverse-action notice principal-reason sample after a SPCP that originated almost no loans to the intended class in a Fair Lending challenge. 2. Exam-response coordinator cannot defend Remove access or reverse the item from adverse-action notice principal-reason sample; Temporary compensating control is what the extract actually supports after a SPCP that originated almost no loans to the intended class. 3. A SPCP that originated almost no loans to the intended class never reached the population in adverse-action notice principal-reason sample — reopen intake, do not close to pause a product. 4. Two facts in adverse-action notice principal-reason sample after a SPCP that originated almost no loans to the intended class conflict for exam-response coordinator; hold this CRA and Special-Purpose Programs file.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in adverse-action notice principal-reason sample. 2. Check HMDA coding and underwriting policy against to pause a product. 3. Compare adverse-action notice principal-reason sample to similarly situated files, second-review notes, and reason codes after a SPCP that originated almost no loans to the intended class. 4. For this Fair Lending CRA and Special-Purpose Programs file, read adverse-action notice principal-reason sample against a SPCP that originated almost no loans to the intended class and write the one fact that would move to pause a product 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 (adverse-action notice principal-reason sample after a SPCP that originated almost no loans to the intended class). If adverse-action notice principal-reason sample cannot force a Fair Lending label under CRA and Special-Purpose Programs, stop. If adverse-action notice principal-reason sample after a SPCP that originated almost no loans to the intended class cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending CRA and Special-Purpose Programs close, exam-response coordinator must do not infer a control or scheme beyond the transaction and entitlement evidence.