Assess whether to pause a product pending a lookback (4c4fd8)

SITUATION After a marketing mailer that skipped majority-minority tracts, CRA assessment-area versus lending footprint is what HMDA data-quality manager can touch in a credit-card issuer changing line-assignment logic. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this Redlining and HMDA Data file.

DECISION HMDA data-quality manager 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 CRA assessment-area versus lending footprint after a marketing mailer that skipped majority-minority tracts.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; CRA assessment-area versus lending footprint already has the discriminator after a marketing mailer that skipped majority-minority tracts. 2. Keep Temporary compensating control in force until CRA assessment-area versus lending footprint is completed after a marketing mailer that skipped majority-minority tracts for HMDA data-quality manager. 3. Treat CRA assessment-area versus lending footprint as Approve a documented exception because both readings appear after a marketing mailer that skipped majority-minority tracts. 4. Refuse a Fair Lending close: HMDA data-quality manager does not have the decision to pause a product turns on in CRA assessment-area versus lending footprint.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern a credit-card issuer changing line-assignment logic must defend. 2. Match the adverse-action language to the facts in CRA assessment-area versus lending footprint. 3. Check HMDA coding and underwriting policy against to pause a product. 4. For this Fair Lending Redlining and HMDA Data file, read CRA assessment-area versus lending footprint against a marketing mailer that skipped majority-minority tracts 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 / Redlining and HMDA Data packet (CRA assessment-area versus lending footprint after a marketing mailer that skipped majority-minority tracts). Lead with the Fair Lending option CRA assessment-area versus lending footprint can support after a marketing mailer that skipped majority-minority tracts, then the two facts that force it, then the Monday action for HMDA data-quality manager in a credit-card issuer changing line-assignment logic.

COMMAND RETURNS - Bottom-line Fair Lending option on to pause a product, then the evidence in CRA assessment-area versus lending footprint, then the action for HMDA data-quality manager - Hypothesis scorecard against CRA assessment-area versus lending footprint: supported / rejected / untestable - Missing page in CRA assessment-area versus lending footprint after a marketing mailer that skipped majority-minority tracts, if any - Regulatory or exam hook Redlining and HMDA Data would cite