Assess whether notices match the actual decisioning reasons (22130c)

SITUATION Examination and Notices work in a manufactured-housing lender with dealer-originated files now turns on notices match the actual because a SPCP that originated almost no loans to the intended class put mortgage pricing residual by prohibited-basis group in play. Community-development lender should say what mortgage pricing residual by prohibited-basis group proves.

DECISION Community-development lender 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 SPCP that originated almost no loans to the intended class.

HYPOTHESES TO TEST 1. Community-development lender can defend Remove access or reverse the item from mortgage pricing residual by prohibited-basis group after a SPCP that originated almost no loans to the intended class in a Fair Lending challenge. 2. Community-development lender cannot defend Remove access or reverse the item from mortgage pricing residual by prohibited-basis group; Temporary compensating control is what the extract actually supports after a SPCP that originated almost no loans to the intended class. 3. A SPCP that originated almost no loans to the intended class never reached the population in mortgage pricing residual by prohibited-basis group — reopen intake, do not close notices match the actual. 4. Two facts in mortgage pricing residual by prohibited-basis group after a SPCP that originated almost no loans to the intended class conflict for community-development lender; hold this Examination and Notices file.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in mortgage pricing residual by prohibited-basis group. 2. Check HMDA coding and underwriting policy against notices match the actual. 3. Compare mortgage pricing residual by prohibited-basis group to similarly situated files, second-review notes, and reason codes after a SPCP that originated almost no loans to the intended class. 4. For this Fair Lending Examination and Notices file, read mortgage pricing residual by prohibited-basis group against a SPCP that originated almost no loans to the intended class and write the one fact that would move notices match the actual for community-development lender.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Examination and Notices packet (mortgage pricing residual by prohibited-basis group after a SPCP that originated almost no loans to the intended class). If mortgage pricing residual by prohibited-basis group cannot force a Fair Lending label under Examination and Notices, stop. Do not invent missing evidence a manufactured-housing lender with dealer-originated files does not have.