Assess whether to pause a product pending a lookback (1e5bf7)

SITUATION Fair-lending officer is responsible for to pause a product in a manufactured-housing lender, using dealer-originated files with small-business decline comparative file set as the only working extract. A branch that stopped taking applications in one ZIP is what reset the timeline for this Fair Lending Redlining and HMDA Data file.

DECISION Fair-lending officer 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 branch that stopped taking applications in one ZIP.

HYPOTHESES TO TEST 1. The population in small-business decline comparative file set is the one a branch that stopped taking applications in one ZIP named, so Remove access or reverse the item follows for this Redlining and HMDA Data file. 2. The population in small-business decline comparative file set is adjacent only to a branch that stopped taking applications in one ZIP; Temporary compensating control is the honest Fair Lending call. 3. A manufactured-housing lender with dealer-originated files already contained a branch that stopped taking applications in one ZIP before small-business decline comparative file set arrived; no new Redlining and HMDA Data path. 4. Provenance on small-business decline comparative file set after a branch that stopped taking applications in one ZIP is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

ANALYSIS REQUIRED 1. Compare small-business decline comparative file set to similarly situated files, second-review notes, and reason codes after a branch that stopped taking applications in one ZIP. 2. Flag any disparate-impact table fair-lending officer cannot explain from small-business decline comparative file set. 3. Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend. 4. For this Fair Lending Redlining and HMDA Data file, read small-business decline comparative file set against a branch that stopped taking applications in one ZIP and write the one fact that would move to pause a product for fair-lending officer.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Redlining and HMDA Data packet (small-business decline comparative file set after a branch that stopped taking applications in one ZIP). The follow-on Redlining and HMDA Data action is what fair-lending officer does next: implement the option, assign an owner, and log the missing fact.