Assess whether to pause a product pending a lookback (0dd86e)

SITUATION After a marketing mailer that skipped majority-minority tracts, small-business decline comparative file set is what exam-response coordinator can touch in a manufactured-housing lender with dealer-originated files. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this CRA and Special-Purpose Programs file.

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 small-business decline comparative file set after a marketing mailer that skipped majority-minority tracts.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; small-business decline comparative file set already has the discriminator after a marketing mailer that skipped majority-minority tracts. 2. Keep Temporary compensating control in force until small-business decline comparative file set is completed after a marketing mailer that skipped majority-minority tracts for exam-response coordinator. 3. Treat small-business decline comparative file set as Approve a documented exception because both readings appear after a marketing mailer that skipped majority-minority tracts. 4. Refuse a Fair Lending close: exam-response coordinator does not have the decision to pause a product turns on in small-business decline comparative file set.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in small-business decline comparative file set. 2. Check HMDA coding and underwriting policy against to pause a product. 3. Compare small-business decline comparative file set to similarly situated files, second-review notes, and reason codes after a marketing mailer that skipped majority-minority tracts. 4. For this Fair Lending CRA and Special-Purpose Programs file, read small-business decline comparative file set against a marketing mailer that skipped majority-minority tracts 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 (small-business decline comparative file set after a marketing mailer that skipped majority-minority tracts). The follow-on CRA and Special-Purpose Programs action is what exam-response coordinator does next: implement the option, assign an owner, and log the missing fact.

COMMAND RETURNS - Bottom-line Fair Lending option on to pause a product, then the evidence in small-business decline comparative file set, then the action for exam-response coordinator - Hypothesis scorecard against small-business decline comparative file set: supported / rejected / untestable - Missing page in small-business decline comparative file set after a marketing mailer that skipped majority-minority tracts, if any - Regulatory or exam hook CRA and Special-Purpose Programs would cite