Assess whether to pause a product pending a lookback (d0c1c3)

SITUATION Fair-lending officer is responsible for to pause a product in a manufactured-housing lender, using dealer-originated files with CRA assessment-area versus lending footprint as the only working extract. A vendor score change with no disparate-impact test is what reset the timeline for this Fair Lending Redlining and HMDA Data file.

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 a vendor score change with no disparate-impact test.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; CRA assessment-area versus lending footprint already has the discriminator after a vendor score change with no disparate-impact test. 2. Keep Temporary compensating control in force until CRA assessment-area versus lending footprint is completed after a vendor score change with no disparate-impact test for fair-lending officer. 3. Treat CRA assessment-area versus lending footprint as Approve a documented exception because both readings appear after a vendor score change with no disparate-impact test. 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. Check HMDA coding and underwriting policy against to pause a product. 2. Compare CRA assessment-area versus lending footprint to similarly situated files, second-review notes, and reason codes after a vendor score change with no disparate-impact test. 3. Flag any disparate-impact table fair-lending officer cannot explain from CRA assessment-area versus lending footprint. 4. For this Fair Lending Redlining and HMDA Data file, read CRA assessment-area versus lending footprint against a vendor score change with no disparate-impact test 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 a vendor score change with no disparate-impact test). If CRA assessment-area versus lending footprint cannot force a Fair Lending label under Redlining and HMDA Data, stop. If CRA assessment-area versus lending footprint after a vendor score change with no disparate-impact test cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending Redlining and HMDA Data close, fair-lending officer must do not infer a control or scheme beyond the transaction and entitlement evidence.