Assess whether to pause a product pending a lookback (4baea3)

SITUATION The working file is SPCP written plan versus actual originations after a branch that stopped taking applications in one ZIP. Fair-lending officer in a manufactured-housing lender with dealer-originated files has to name Remove access or reverse the item or Temporary compensating control 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 SPCP written plan versus actual originations after a branch that stopped taking applications in one ZIP.

HYPOTHESES TO TEST 1. The population in SPCP written plan versus actual originations 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 SPCP written plan versus actual originations 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 SPCP written plan versus actual originations arrived; no new Redlining and HMDA Data path. 4. Provenance on SPCP written plan versus actual originations 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. Match the adverse-action language to the facts in SPCP written plan versus actual originations. 2. Check HMDA coding and underwriting policy against to pause a product. 3. Compare SPCP written plan versus actual originations to similarly situated files, second-review notes, and reason codes after a branch that stopped taking applications in one ZIP. 4. For this Fair Lending Redlining and HMDA Data file, read SPCP written plan versus actual originations 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 (SPCP written plan versus actual originations after a branch that stopped taking applications in one ZIP). Lead with the Fair Lending option SPCP written plan versus actual originations can support after a branch that stopped taking applications in one ZIP, then the two facts that force it, then the Monday action for fair-lending officer in a manufactured-housing lender with dealer-originated files.