Assess whether to pause a product pending a lookback from HMDA LAR validity

SITUATION Community-development lender in a bank with thin HMDA LAR quality has one working extract — HMDA LAR validity and quality edits — after a branch that stopped taking applications in one ZIP. If HMDA LAR validity and quality edits cannot support to pause a product, the only defensible Fair Lending output is hold.

DECISION Community-development lender 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 HMDA LAR validity and quality edits after a branch that stopped taking applications in one ZIP.

HYPOTHESES TO TEST 1. Community-development lender can defend Remove access or reverse the item from HMDA LAR validity and quality edits after a branch that stopped taking applications in one ZIP in a Fair Lending challenge. 2. Community-development lender cannot defend Remove access or reverse the item from HMDA LAR validity and quality edits; Temporary compensating control is what the extract actually supports after a branch that stopped taking applications in one ZIP. 3. A branch that stopped taking applications in one ZIP never reached the population in HMDA LAR validity and quality edits — reopen intake, do not close to pause a product. 4. Two facts in HMDA LAR validity and quality edits after a branch that stopped taking applications in one ZIP conflict for community-development lender; hold this Pricing and Credit Limits file.

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 HMDA LAR validity and quality edits. 3. Check HMDA coding and underwriting policy against to pause a product. 4. For this Fair Lending Pricing and Credit Limits file, read HMDA LAR validity and quality edits against a branch that stopped taking applications in one ZIP and write the one fact that would move to pause a product for community-development lender.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Pricing and Credit Limits packet (HMDA LAR validity and quality edits after a branch that stopped taking applications in one ZIP). The follow-on Pricing and Credit Limits action is what community-development lender 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 HMDA LAR validity and quality edits, then the action for community-development lender - Hypothesis scorecard against HMDA LAR validity and quality edits: supported / rejected / untestable - Pricing and Credit Limits finding in HMDA LAR validity and quality edits that a second reviewer can re-perform - Missing page in HMDA LAR validity and quality edits after a branch that stopped taking applications in one ZIP, if any