Assess whether to pause a product pending a lookback (acb03b)

SITUATION CRA strategist in a bank with thin HMDA LAR quality has one working extract — geographic application and origination heat map — after a SPCP that originated almost no loans to the intended class. CRA strategist in a bank with thin HMDA LAR quality has geographic application and origination heat map after a SPCP that originated almost no loans to the intended class. If that extract cannot support to pause a product, the only defensible Fair Lending Examination and Notices output is hold.

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 geographic application and origination heat map after a SPCP that originated almost no loans to the intended class.

HYPOTHESES TO TEST 1. The population in geographic application and origination heat map is the one a SPCP that originated almost no loans to the intended class named, so Remove access or reverse the item follows for this Examination and Notices file. 2. The population in geographic application and origination heat map is adjacent only to a SPCP that originated almost no loans to the intended class; Temporary compensating control is the honest Fair Lending call. 3. A bank with thin HMDA LAR quality already contained a SPCP that originated almost no loans to the intended class before geographic application and origination heat map arrived; no new Examination and Notices path. 4. Provenance on geographic application and origination heat map after a SPCP that originated almost no loans to the intended class is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

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 geographic application and origination heat map. 3. Check HMDA coding and underwriting policy against to pause a product. 4. For this Fair Lending Examination and Notices file, read geographic application and origination heat map against a SPCP that originated almost no loans to the intended class 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 (geographic application and origination heat map after a SPCP that originated almost no loans to the intended class). The follow-on Examination and Notices action is what CRA strategist does next: implement the option, assign an owner, and log the missing fact.