Assess whether to pause a product pending a lookback (c701d1)

SITUATION SPCP written plan versus actual originations arrived with a DOJ or CFPB monitor request for pricing files for exam-response coordinator. That is a Fair Lending CRA and Special-Purpose Programs decision on to pause a product in a manufactured-housing lender with dealer-originated files.

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 SPCP written plan versus actual originations after a DOJ or CFPB monitor request for pricing files.

HYPOTHESES TO TEST 1. A DOJ or CFPB monitor request for pricing files is noise around an already-controlled CRA and Special-Purpose Programs process in a manufactured-housing lender with dealer-originated files, given SPCP written plan versus actual originations. 2. A DOJ or CFPB monitor request for pricing files is the event in SPCP written plan versus actual originations that forces Remove access or reverse the item for exam-response coordinator under Fair Lending. 3. SPCP written plan versus actual originations shows a one-file miss after a DOJ or CFPB monitor request for pricing files, not a CRA and Special-Purpose Programs program failure. 4. SPCP written plan versus actual originations cannot decide to pause a product yet after a DOJ or CFPB monitor request for pricing files; hold is the only Fair Lending close a manufactured-housing lender with dealer-originated files can defend.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend. 2. Match the adverse-action language to the facts in SPCP written plan versus actual originations. 3. Check HMDA coding and underwriting policy against to pause a product. 4. For this Fair Lending CRA and Special-Purpose Programs file, read SPCP written plan versus actual originations against a DOJ or CFPB monitor request for pricing files 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 (SPCP written plan versus actual originations after a DOJ or CFPB monitor request for pricing files). 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.

COMMAND RETURNS - Bottom-line Fair Lending option on to pause a product, then the evidence in SPCP written plan versus actual originations, then the action for exam-response coordinator - Hypothesis scorecard against SPCP written plan versus actual originations: supported / rejected / untestable - Named option among Remove access or reverse the item, Temporary compensating control, Approve a documented exception and the fact that kills the others - Owner and next date for exam-response coordinator in a manufactured-housing lender with dealer-originated files