Community-development lender must resolve whether to pause a product pending

Situation

To pause a product sits with community-development lender because a branch that stopped taking applications in one ZIP hit a bank with thin HMDA LAR quality. Evidence is model-reason-code mapping that does not match notices; write the Fair Lending Pricing and Credit Limits option that extract can carry.

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 model-reason-code mapping that does not match notices after a branch that stopped taking applications in one ZIP.

Hypotheses to test

• The population in model-reason-code mapping that does not match notices is the one a branch that stopped taking applications in one ZIP named, so Remove access or reverse the item follows for this Pricing and Credit Limits file.
• The population in model-reason-code mapping that does not match notices is adjacent only to a branch that stopped taking applications in one ZIP; Temporary compensating control is the honest Fair Lending call.
• A bank with thin HMDA LAR quality already contained a branch that stopped taking applications in one ZIP before model-reason-code mapping that does not match notices arrived; no new Pricing and Credit Limits path.
• Provenance on model-reason-code mapping that does not match notices after a branch that stopped taking applications in one ZIP is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Match the adverse-action language to the facts in model-reason-code mapping that does not match notices.
• Check HMDA coding and underwriting policy against to pause a product.
• Compare model-reason-code mapping that does not match notices to similarly situated files, second-review notes, and reason codes after a branch that stopped taking applications in one ZIP.
• For this Fair Lending Pricing and Credit Limits file, read model-reason-code mapping that does not match notices 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 (model-reason-code mapping that does not match notices 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.