Assess whether to pause a product pending a lookback (c83ee6)

SITUATION Examination and Notices work in a credit union rolling out a special-purpose credit program now turns on to pause a product because a DOJ or CFPB monitor request for pricing files put HMDA LAR validity and quality edits in play. Second-review underwriter should say what HMDA LAR validity and quality edits proves.

DECISION Second-review underwriter in a credit union rolling out a special-purpose credit program 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 DOJ or CFPB monitor request for pricing files.

HYPOTHESES TO TEST 1. Second-review underwriter can defend Remove access or reverse the item from HMDA LAR validity and quality edits after a DOJ or CFPB monitor request for pricing files in a Fair Lending challenge. 2. Second-review underwriter 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 DOJ or CFPB monitor request for pricing files. 3. A DOJ or CFPB monitor request for pricing files 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 DOJ or CFPB monitor request for pricing files conflict for second-review underwriter; hold this Examination and Notices file.

ANALYSIS REQUIRED 1. Flag any disparate-impact table second-review underwriter cannot explain from HMDA LAR validity and quality edits. 2. Test a documented exception versus a pattern a credit union rolling out a special-purpose credit program must defend. 3. Match the adverse-action language to the facts in HMDA LAR validity and quality edits. 4. For this Fair Lending Examination and Notices file, read HMDA LAR validity and quality edits against a DOJ or CFPB monitor request for pricing files and write the one fact that would move to pause a product for second-review underwriter.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Examination and Notices packet (HMDA LAR validity and quality edits after a DOJ or CFPB monitor request for pricing files). If HMDA LAR validity and quality edits cannot force a Fair Lending label under Examination and Notices, stop. Do not invent missing evidence a credit union rolling out a special-purpose credit program does not have.

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 second-review underwriter - Hypothesis scorecard against HMDA LAR validity and quality edits: supported / rejected / untestable - Regulatory or exam hook Examination and Notices would cite - Examination and Notices finding in HMDA LAR validity and quality edits that a second reviewer can re-perform