Assess whether to pause a product pending a lookback (1fa3e6)

SITUATION After an exception rate twice as high for one group after credit controls, HMDA LAR validity and quality edits is what HMDA data-quality manager can touch in a credit union rolling out a special-purpose credit program. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this CRA and Special-Purpose Programs file.

DECISION HMDA data-quality manager 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 an exception rate twice as high for one group after credit controls.

HYPOTHESES TO TEST 1. An exception rate twice as high for one group after credit controls is noise around an already-controlled CRA and Special-Purpose Programs process in a credit union rolling out a special-purpose credit program, given HMDA LAR validity and quality edits. 2. An exception rate twice as high for one group after credit controls is the event in HMDA LAR validity and quality edits that forces Remove access or reverse the item for HMDA data-quality manager under Fair Lending. 3. HMDA LAR validity and quality edits shows a one-file miss after an exception rate twice as high for one group after credit controls, not a CRA and Special-Purpose Programs program failure. 4. HMDA LAR validity and quality edits cannot decide to pause a product yet after an exception rate twice as high for one group after credit controls; hold is the only Fair Lending close a credit union rolling out a special-purpose credit program can defend.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in HMDA LAR validity and quality edits. 2. Check HMDA coding and underwriting policy against to pause a product. 3. Compare HMDA LAR validity and quality edits to similarly situated files, second-review notes, and reason codes after an exception rate twice as high for one group after credit controls. 4. For this Fair Lending CRA and Special-Purpose Programs file, read HMDA LAR validity and quality edits against an exception rate twice as high for one group after credit controls and write the one fact that would move to pause a product for HMDA data-quality manager.

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 (HMDA LAR validity and quality edits after an exception rate twice as high for one group after credit controls). Lead with the Fair Lending option HMDA LAR validity and quality edits can support after an exception rate twice as high for one group after credit controls, then the two facts that force it, then the Monday action for HMDA data-quality manager in a credit union rolling out a special-purpose credit program.