Assess whether to pause a product pending a lookback (e9b43a)

SITUATION A bank with thin HMDA LAR quality cannot treat a marketing mailer that skipped majority-minority tracts as incidental context on geographic application and origination heat map. CRA strategist must close to pause a product from that extract under Fair Lending / Examination and Notices.

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 marketing mailer that skipped majority-minority tracts.

HYPOTHESES TO TEST 1. The population in geographic application and origination heat map is the one a marketing mailer that skipped majority-minority tracts 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 marketing mailer that skipped majority-minority tracts; Temporary compensating control is the honest Fair Lending call. 3. A bank with thin HMDA LAR quality already contained a marketing mailer that skipped majority-minority tracts 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 marketing mailer that skipped majority-minority tracts is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against to pause a product. 2. Compare geographic application and origination heat map to similarly situated files, second-review notes, and reason codes after a marketing mailer that skipped majority-minority tracts. 3. Flag any disparate-impact table CRA strategist cannot explain from geographic application and origination heat map. 4. For this Fair Lending Examination and Notices file, read geographic application and origination heat map against a marketing mailer that skipped majority-minority tracts 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 marketing mailer that skipped majority-minority tracts). If geographic application and origination heat map cannot force a Fair Lending label under Examination and Notices, stop. If geographic application and origination heat map after a marketing mailer that skipped majority-minority tracts cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending Examination and Notices close, CRA strategist must do not infer a control or scheme beyond the transaction and entitlement evidence.