Assess whether to pause a product pending a lookback (2c6038)

SITUATION In a manufactured-housing lender with dealer-originated files, small-business decline comparative file set is the evidence after an exception rate twice as high for one group after credit controls. Exam-response coordinator has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending CRA and Special-Purpose Programs close using small-business decline comparative file set.

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 small-business decline comparative file set after an exception rate twice as high for one group after credit controls.

HYPOTHESES TO TEST 1. Small-business decline comparative file set reads as Remove access or reverse the item once an exception rate twice as high for one group after credit controls is lined up to the same Fair Lending population. 2. Small-business decline comparative file set is closer to Temporary compensating control after an exception rate twice as high for one group after credit controls; Remove access or reverse the item would over-claim this CRA and Special-Purpose Programs extract. 3. Approve a documented exception is still live in small-business decline comparative file set for exam-response coordinator in a manufactured-housing lender with dealer-originated files. 4. Small-business decline comparative file set is missing the fact exam-response coordinator needs after an exception rate twice as high for one group after credit controls; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against to pause a product. 2. Compare small-business decline comparative file set to similarly situated files, second-review notes, and reason codes after an exception rate twice as high for one group after credit controls. 3. Flag any disparate-impact table exam-response coordinator cannot explain from small-business decline comparative file set. 4. For this Fair Lending CRA and Special-Purpose Programs file, read small-business decline comparative file set against an exception rate twice as high for one group after credit controls 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 (small-business decline comparative file set after an exception rate twice as high for one group after credit controls). The follow-on CRA and Special-Purpose Programs action is what exam-response coordinator does next: implement the option, assign an owner, and log the missing fact.