Assess whether to pause a product pending a lookback (576bde)

SITUATION Exam-response coordinator in a manufactured-housing lender with dealer-originated files has one working extract — SPCP written plan versus actual originations — after a marketing mailer that skipped majority-minority tracts. If SPCP written plan versus actual originations cannot support to pause a product, the only defensible Fair Lending output is hold.

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 marketing mailer that skipped majority-minority tracts.

HYPOTHESES TO TEST 1. A marketing mailer that skipped majority-minority tracts 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 marketing mailer that skipped majority-minority tracts 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 marketing mailer that skipped majority-minority tracts, 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 marketing mailer that skipped majority-minority tracts; hold is the only Fair Lending close a manufactured-housing lender with dealer-originated files can defend.

ANALYSIS REQUIRED 1. Flag any disparate-impact table exam-response coordinator cannot explain from SPCP written plan versus actual originations. 2. Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend. 3. Match the adverse-action language to the facts in SPCP written plan versus actual originations. 4. For this Fair Lending CRA and Special-Purpose Programs file, read SPCP written plan versus actual originations against a marketing mailer that skipped majority-minority tracts 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 marketing mailer that skipped majority-minority tracts). 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.