Assess whether to pause a product pending a lookback (3bd310)

SITUATION Exam-response coordinator in a manufactured-housing lender with dealer-originated files has one working extract — mortgage pricing residual by prohibited-basis group — after a vendor score change with no disparate-impact test. Exam-response coordinator in a manufactured-housing lender with dealer-originated files has mortgage pricing residual by prohibited-basis group after a vendor score change with no disparate-impact test. 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 mortgage pricing residual by prohibited-basis group after a vendor score change with no disparate-impact test.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; mortgage pricing residual by prohibited-basis group already has the discriminator after a vendor score change with no disparate-impact test. 2. Keep Temporary compensating control in force until mortgage pricing residual by prohibited-basis group is completed after a vendor score change with no disparate-impact test for exam-response coordinator. 3. Treat mortgage pricing residual by prohibited-basis group 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: exam-response coordinator does not have the decision to pause a product turns on in mortgage pricing residual by prohibited-basis group.

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 mortgage pricing residual by prohibited-basis group. 3. Check HMDA coding and underwriting policy against to pause a product. 4. For this Fair Lending CRA and Special-Purpose Programs file, read mortgage pricing residual by prohibited-basis group against a vendor score change with no disparate-impact test 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 (mortgage pricing residual by prohibited-basis group after a vendor score change with no disparate-impact test). Lead with the Fair Lending option mortgage pricing residual by prohibited-basis group can support after a vendor score change with no disparate-impact test, then the two facts that force it, then the Monday action for exam-response coordinator in a manufactured-housing lender with dealer-originated files.