Whether to pause a product pending a lookback from SPCP written plan versus

SITUATION After a notice that cites 'other' as the principal reason 40% of the time, SPCP written plan versus actual originations is what HMDA data-quality manager can touch in a lender expanding into majority-minority census tracts. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this Pricing and Credit Limits file.

DECISION HMDA data-quality manager in a lender expanding into majority-minority census tracts 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 notice that cites 'other' as the principal reason 40% of the time.

HYPOTHESES TO TEST 1. HMDA data-quality manager can defend Remove access or reverse the item from SPCP written plan versus actual originations after a notice that cites 'other' as the principal reason 40% of the time in a Fair Lending challenge. 2. HMDA data-quality manager cannot defend Remove access or reverse the item from SPCP written plan versus actual originations; Temporary compensating control is what the extract actually supports after a notice that cites 'other' as the principal reason 40% of the time. 3. A notice that cites 'other' as the principal reason 40% of the time never reached the population in SPCP written plan versus actual originations — reopen intake, do not close to pause a product. 4. Two facts in SPCP written plan versus actual originations after a notice that cites 'other' as the principal reason 40% of the time conflict for HMDA data-quality manager; hold this Pricing and Credit Limits file.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against to pause a product. 2. Compare SPCP written plan versus actual originations to similarly situated files, second-review notes, and reason codes after a notice that cites 'other' as the principal reason 40% of the time. 3. Flag any disparate-impact table HMDA data-quality manager cannot explain from SPCP written plan versus actual originations. 4. For this Fair Lending Pricing and Credit Limits file, read SPCP written plan versus actual originations against a notice that cites 'other' as the principal reason 40% of the time and write the one fact that would move to pause a product for HMDA data-quality manager.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Pricing and Credit Limits packet (SPCP written plan versus actual originations after a notice that cites 'other' as the principal reason 40% of the time). Lead with the Fair Lending option SPCP written plan versus actual originations can support after a notice that cites 'other' as the principal reason 40% of the time, then the two facts that force it, then the Monday action for HMDA data-quality manager in a lender expanding into majority-minority census tracts.