Assess whether to pause a product pending a lookback (a12842)

SITUATION A board asking if the bank should settle a matched-pair study put manufactured-housing dealer overlay notes in front of adverse-action notice operations lead in a lender expanding into majority-minority census tracts. This Fair Lending / Redlining and HMDA Data close is to pause a product from manufactured-housing dealer overlay notes, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

DECISION Adverse-action notice operations lead in a lender expanding into majority-minority census tracts must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using manufactured-housing dealer overlay notes after a board asking if the bank should settle a matched-pair study.

HYPOTHESES TO TEST 1. A board asking if the bank should settle a matched-pair study is noise around an already-controlled Redlining and HMDA Data process in a lender expanding into majority-minority census tracts, given manufactured-housing dealer overlay notes. 2. A board asking if the bank should settle a matched-pair study is the event in manufactured-housing dealer overlay notes that forces Remove access or reverse the item for adverse-action notice operations lead under Fair Lending. 3. Manufactured-housing dealer overlay notes shows a one-file miss after a board asking if the bank should settle a matched-pair study, not a Redlining and HMDA Data program failure. 4. Manufactured-housing dealer overlay notes cannot decide to pause a product yet after a board asking if the bank should settle a matched-pair study; hold is the only Fair Lending close a lender expanding into majority-minority census tracts can defend.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against to pause a product. 2. Compare manufactured-housing dealer overlay notes to similarly situated files, second-review notes, and reason codes after a board asking if the bank should settle a matched-pair study. 3. Flag any disparate-impact table adverse-action notice operations lead cannot explain from manufactured-housing dealer overlay notes. 4. For this Fair Lending Redlining and HMDA Data file, read manufactured-housing dealer overlay notes against a board asking if the bank should settle a matched-pair study and write the one fact that would move to pause a product for adverse-action notice operations lead.

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 (manufactured-housing dealer overlay notes after a board asking if the bank should settle a matched-pair study). The follow-on Redlining and HMDA Data action is what adverse-action notice operations lead does next: implement the option, assign an owner, and log the missing fact.