CRA strategist must resolve whether to pause a product pending a lookback

Situation

CRA strategist owns to pause a product inside a manufactured-housing lender with dealer-originated files with SPCP written plan versus actual originations as the only packet. A SPCP that originated almost no loans to the intended class is what changed the clock for this Fair Lending Pricing and Credit Limits file.

Decision

CRA strategist 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 a SPCP that originated almost no loans to the intended class.

Hypotheses to test

• A SPCP that originated almost no loans to the intended class is noise around an already-controlled Pricing and Credit Limits process in a manufactured-housing lender with dealer-originated files, given SPCP written plan versus actual originations.
• A SPCP that originated almost no loans to the intended class is the event in SPCP written plan versus actual originations that forces Remove access or reverse the item for CRA strategist under Fair Lending.
• SPCP written plan versus actual originations shows a one-file miss after a SPCP that originated almost no loans to the intended class, not a Pricing and Credit Limits program failure.
• SPCP written plan versus actual originations cannot decide to pause a product yet after a SPCP that originated almost no loans to the intended class; hold is the only Fair Lending close a manufactured-housing lender with dealer-originated files can defend.

Analysis required

• Check HMDA coding and underwriting policy against to pause a product.
• Compare SPCP written plan versus actual originations to similarly situated files, second-review notes, and reason codes after a SPCP that originated almost no loans to the intended class.
• Flag any disparate-impact table CRA strategist cannot explain from SPCP written plan versus actual originations.
• For this Fair Lending Pricing and Credit Limits file, read SPCP written plan versus actual originations against a SPCP that originated almost no loans to the intended class and write the one fact that would move to pause a product for CRA strategist.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Pricing and Credit Limits packet (SPCP written plan versus actual originations after a SPCP that originated almost no loans to the intended class). The follow-on Pricing and Credit Limits action is what CRA strategist does next: implement the option, assign an owner, and log the missing fact.