Assess whether to pause a product pending a lookback (9e1bb0)

SITUATION The working file is CRA assessment-area versus lending footprint after a notice that cites 'other' as the principal reason 40% of the time. Fair-lending officer in a bank with thin HMDA LAR quality has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending CRA and Special-Purpose Programs file.

DECISION Fair-lending officer 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 CRA assessment-area versus lending footprint after a notice that cites 'other' as the principal reason 40% of the time.

HYPOTHESES TO TEST 1. A notice that cites 'other' as the principal reason 40% of the time is noise around an already-controlled CRA and Special-Purpose Programs process in a bank with thin HMDA LAR quality, given CRA assessment-area versus lending footprint. 2. A notice that cites 'other' as the principal reason 40% of the time is the event in CRA assessment-area versus lending footprint that forces Remove access or reverse the item for fair-lending officer under Fair Lending. 3. CRA assessment-area versus lending footprint shows a one-file miss after a notice that cites 'other' as the principal reason 40% of the time, not a CRA and Special-Purpose Programs program failure. 4. CRA assessment-area versus lending footprint cannot decide to pause a product yet after a notice that cites 'other' as the principal reason 40% of the time; hold is the only Fair Lending close a bank with thin HMDA LAR quality can defend.

ANALYSIS REQUIRED 1. Flag any disparate-impact table fair-lending officer cannot explain from CRA assessment-area versus lending footprint. 2. Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend. 3. Match the adverse-action language to the facts in CRA assessment-area versus lending footprint. 4. For this Fair Lending CRA and Special-Purpose Programs file, read CRA assessment-area versus lending footprint 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 fair-lending officer.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / CRA and Special-Purpose Programs packet (CRA assessment-area versus lending footprint after a notice that cites 'other' as the principal reason 40% of the time). The follow-on CRA and Special-Purpose Programs action is what fair-lending officer does next: implement the option, assign an owner, and log the missing fact.

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 fair-lending officer - Hypothesis scorecard against CRA assessment-area versus lending footprint: supported / rejected / untestable - What changes to pause a product if a notice that cites 'other' as the principal reason 40% of the time 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