Assess whether to pause a product pending a lookback (1e6686)

SITUATION In a manufactured-housing lender with dealer-originated files, CRA assessment-area versus lending footprint is the evidence after an exception rate twice as high for one group after credit controls. Fair-lending officer has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending Redlining and HMDA Data close using CRA assessment-area versus lending footprint.

DECISION Fair-lending officer 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 an exception rate twice as high for one group after credit controls.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; CRA assessment-area versus lending footprint already has the discriminator after an exception rate twice as high for one group after credit controls. 2. Keep Temporary compensating control in force until CRA assessment-area versus lending footprint is completed after an exception rate twice as high for one group after credit controls for fair-lending officer. 3. Treat CRA assessment-area versus lending footprint as Approve a documented exception because both readings appear after an exception rate twice as high for one group after credit controls. 4. Refuse a Fair Lending close: fair-lending officer does not have the decision to pause a product turns on in CRA assessment-area versus lending footprint.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend. 2. Match the adverse-action language to the facts in CRA assessment-area versus lending footprint. 3. Check HMDA coding and underwriting policy against to pause a product. 4. For this Fair Lending Redlining and HMDA Data file, read CRA assessment-area versus lending footprint against an exception rate twice as high for one group after credit controls and write the one fact that would move to pause a product for fair-lending officer.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Redlining and HMDA Data packet (CRA assessment-area versus lending footprint after an exception rate twice as high for one group after credit controls). Lead with the Fair Lending option CRA assessment-area versus lending footprint can support after an exception rate twice as high for one group after credit controls, then the two facts that force it, then the Monday action for fair-lending officer in a manufactured-housing lender with dealer-originated files.