Assess whether to pause a product pending a lookback (ec62c5)

SITUATION An underwriter chat that used coded language put geographic application and origination heat map in front of community-development lender in a manufactured-housing lender with dealer-originated files. This Fair Lending / Examination and Notices close is to pause a product from geographic application and origination heat map, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

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 geographic application and origination heat map after an underwriter chat that used coded language.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; geographic application and origination heat map already has the discriminator after an underwriter chat that used coded language. 2. Keep Temporary compensating control in force until geographic application and origination heat map is completed after an underwriter chat that used coded language for community-development lender. 3. Treat geographic application and origination heat map as Approve a documented exception because both readings appear after an underwriter chat that used coded language. 4. Refuse a Fair Lending close: community-development lender does not have the decision to pause a product turns on in geographic application and origination heat map.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against to pause a product. 2. Compare geographic application and origination heat map to similarly situated files, second-review notes, and reason codes after an underwriter chat that used coded language. 3. Flag any disparate-impact table community-development lender cannot explain from geographic application and origination heat map. 4. For this Fair Lending Examination and Notices file, read geographic application and origination heat map against an underwriter chat that used coded language and write the one fact that would move to pause a product 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 (geographic application and origination heat map after an underwriter chat that used coded language). If geographic application and origination heat map 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.