Assess whether to pause a product pending a lookback (de357b)

SITUATION CRA strategist is responsible for to pause a product in a bank, using thin HMDA LAR quality with appraisal-gap outcomes in majority-minority tracts as the only working extract. A HMDA resubmission that still fails quality edits is what reset the timeline for this Fair Lending Examination and Notices file.

DECISION CRA strategist in a bank with thin HMDA LAR quality must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using appraisal-gap outcomes in majority-minority tracts after a HMDA resubmission that still fails quality edits.

HYPOTHESES TO TEST 1. CRA strategist can defend Remove access or reverse the item from appraisal-gap outcomes in majority-minority tracts after a HMDA resubmission that still fails quality edits in a Fair Lending challenge. 2. CRA strategist cannot defend Remove access or reverse the item from appraisal-gap outcomes in majority-minority tracts; Temporary compensating control is what the extract actually supports after a HMDA resubmission that still fails quality edits. 3. A HMDA resubmission that still fails quality edits never reached the population in appraisal-gap outcomes in majority-minority tracts — reopen intake, do not close to pause a product. 4. Two facts in appraisal-gap outcomes in majority-minority tracts after a HMDA resubmission that still fails quality edits conflict for CRA strategist; hold this Examination and Notices file.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend. 2. Match the adverse-action language to the facts in appraisal-gap outcomes in majority-minority tracts. 3. Check HMDA coding and underwriting policy against to pause a product. 4. For this Fair Lending Examination and Notices file, read appraisal-gap outcomes in majority-minority tracts against a HMDA resubmission that still fails quality edits and write the one fact that would move to pause a product for CRA strategist.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Examination and Notices packet (appraisal-gap outcomes in majority-minority tracts after a HMDA resubmission that still fails quality edits). Lead with the Fair Lending option appraisal-gap outcomes in majority-minority tracts can support after a HMDA resubmission that still fails quality edits, then the two facts that force it, then the Monday action for CRA strategist in a bank with thin HMDA LAR quality.

COMMAND RETURNS - Bottom-line Fair Lending option on to pause a product, then the evidence in appraisal-gap outcomes in majority-minority tracts, then the action for CRA strategist - Hypothesis scorecard against appraisal-gap outcomes in majority-minority tracts: supported / rejected / untestable - What changes to pause a product if a HMDA resubmission that still fails quality edits is later withdrawn - Named option among Remove access or reverse the item, Temporary compensating control, Approve a documented exception and the fact that kills the others