Assess whether to pause a product pending a lookback (5376f1)

SITUATION A branch that stopped taking applications in one ZIP put credit-card limit assignment disparity table in front of CRA strategist in a mortgage company after a pricing-regression spike. This Fair Lending / CRA and Special-Purpose Programs close is to pause a product from credit-card limit assignment disparity table, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

DECISION CRA strategist 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 credit-card limit assignment disparity table after a branch that stopped taking applications in one ZIP.

HYPOTHESES TO TEST 1. Credit-card limit assignment disparity table reads as Remove access or reverse the item once a branch that stopped taking applications in one ZIP is lined up to the same Fair Lending population. 2. Credit-card limit assignment disparity table is closer to Temporary compensating control after a branch that stopped taking applications in one ZIP; Remove access or reverse the item would over-claim this CRA and Special-Purpose Programs extract. 3. Approve a documented exception is still live in credit-card limit assignment disparity table for CRA strategist in a mortgage company after a pricing-regression spike. 4. Credit-card limit assignment disparity table is missing the fact CRA strategist needs after a branch that stopped taking applications in one ZIP; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against to pause a product. 2. Compare credit-card limit assignment disparity table to similarly situated files, second-review notes, and reason codes after a branch that stopped taking applications in one ZIP. 3. Flag any disparate-impact table CRA strategist cannot explain from credit-card limit assignment disparity table. 4. For this Fair Lending CRA and Special-Purpose Programs file, read credit-card limit assignment disparity table against a branch that stopped taking applications in one ZIP 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 / CRA and Special-Purpose Programs packet (credit-card limit assignment disparity table after a branch that stopped taking applications in one ZIP). If credit-card limit assignment disparity table cannot force a Fair Lending label under CRA and Special-Purpose Programs, stop. If credit-card limit assignment disparity table after a branch that stopped taking applications in one ZIP cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending CRA and Special-Purpose Programs close, CRA strategist must do not infer a control or scheme beyond the transaction and entitlement evidence.