Assess whether to pause a product pending a lookback (845c35)

SITUATION After a marketing mailer that skipped majority-minority tracts, adverse-action notice principal-reason sample is what community-development lender can touch in a mortgage company after a pricing-regression spike. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this Redlining and HMDA Data file.

DECISION Community-development lender in a mortgage company after a pricing-regression spike 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 marketing mailer that skipped majority-minority tracts.

HYPOTHESES TO TEST 1. Community-development lender can defend Remove access or reverse the item from adverse-action notice principal-reason sample after a marketing mailer that skipped majority-minority tracts in a Fair Lending challenge. 2. Community-development lender 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 marketing mailer that skipped majority-minority tracts. 3. A marketing mailer that skipped majority-minority tracts 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 marketing mailer that skipped majority-minority tracts conflict for community-development lender; hold this Redlining and HMDA Data 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 marketing mailer that skipped majority-minority tracts. 3. Flag any disparate-impact table community-development lender cannot explain from adverse-action notice principal-reason sample. 4. For this Fair Lending Redlining and HMDA Data file, read adverse-action notice principal-reason sample against a marketing mailer that skipped majority-minority tracts and write the one fact that would move to pause a product for community-development lender.

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 (adverse-action notice principal-reason sample after a marketing mailer that skipped majority-minority tracts). Lead with the Fair Lending option adverse-action notice principal-reason sample can support after a marketing mailer that skipped majority-minority tracts, then the two facts that force it, then the Monday action for community-development lender in a mortgage company after a pricing-regression spike.