Assess whether to pause a product pending a lookback (58ed14)

SITUATION Exam-response coordinator in a manufactured-housing lender with dealer-originated files has one working extract — SPCP written plan versus actual originations — after an underwriter chat that used coded language. If SPCP written plan versus actual originations cannot support to pause a product, the only defensible Fair Lending 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 SPCP written plan versus actual originations after an underwriter chat that used coded language.

HYPOTHESES TO TEST 1. The population in SPCP written plan versus actual originations is the one an underwriter chat that used coded language named, so Remove access or reverse the item follows for this CRA and Special-Purpose Programs file. 2. The population in SPCP written plan versus actual originations is adjacent only to an underwriter chat that used coded language; Temporary compensating control is the honest Fair Lending call. 3. A manufactured-housing lender with dealer-originated files already contained an underwriter chat that used coded language before SPCP written plan versus actual originations arrived; no new CRA and Special-Purpose Programs path. 4. Provenance on SPCP written plan versus actual originations after an underwriter chat that used coded language is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

ANALYSIS REQUIRED 1. Compare SPCP written plan versus actual originations to similarly situated files, second-review notes, and reason codes after an underwriter chat that used coded language. 2. Flag any disparate-impact table exam-response coordinator cannot explain from SPCP written plan versus actual originations. 3. Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend. 4. For this Fair Lending CRA and Special-Purpose Programs file, read SPCP written plan versus actual originations against an underwriter chat that used coded language 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 (SPCP written plan versus actual originations after an underwriter chat that used coded language). Lead with the Fair Lending option SPCP written plan versus actual originations can support after an underwriter chat that used coded language, then the two facts that force it, then the Monday action for exam-response coordinator in a manufactured-housing lender with dealer-originated files.