Assess whether to pause a product pending a lookback (af8856)

SITUATION Examination and Notices work in a credit-card issuer changing line-assignment logic now turns on to pause a product because a CRA PE that called the assessment area too narrow put adverse-action notice principal-reason sample in play. Adverse-action notice operations lead should say what adverse-action notice principal-reason sample proves.

DECISION Adverse-action notice operations lead in a credit-card issuer changing line-assignment logic must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using adverse-action notice principal-reason sample after a CRA PE that called the assessment area too narrow.

HYPOTHESES TO TEST 1. Adverse-action notice operations lead can defend Remove access or reverse the item from adverse-action notice principal-reason sample after a CRA PE that called the assessment area too narrow in a Fair Lending challenge. 2. Adverse-action notice operations lead cannot defend Remove access or reverse the item from adverse-action notice principal-reason sample; Temporary compensating control is what the extract actually supports after a CRA PE that called the assessment area too narrow. 3. A CRA PE that called the assessment area too narrow never reached the population in adverse-action notice principal-reason sample — reopen intake, do not close to pause a product. 4. Two facts in adverse-action notice principal-reason sample after a CRA PE that called the assessment area too narrow conflict for adverse-action notice operations lead; hold this Examination and Notices file.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against to pause a product. 2. Compare adverse-action notice principal-reason sample to similarly situated files, second-review notes, and reason codes after a CRA PE that called the assessment area too narrow. 3. Flag any disparate-impact table adverse-action notice operations lead cannot explain from adverse-action notice principal-reason sample. 4. For this Fair Lending Examination and Notices file, read adverse-action notice principal-reason sample against a CRA PE that called the assessment area too narrow and write the one fact that would move to pause a product for adverse-action notice operations lead.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Examination and Notices packet (adverse-action notice principal-reason sample after a CRA PE that called the assessment area too narrow). Lead with the Fair Lending option adverse-action notice principal-reason sample can support after a CRA PE that called the assessment area too narrow, then the two facts that force it, then the Monday action for adverse-action notice operations lead in a credit-card issuer changing line-assignment logic.