Assess whether to pause a product pending a lookback (2e3e2f)

SITUATION In a bank with thin HMDA LAR quality, model-reason-code mapping that does not match notices is the evidence after a CRA PE that called the assessment area too narrow. Fair-lending officer has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending CRA and Special-Purpose Programs close using model-reason-code mapping that does not match notices.

DECISION Fair-lending officer 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 CRA PE that called the assessment area too narrow.

HYPOTHESES TO TEST 1. The population in model-reason-code mapping that does not match notices is the one a CRA PE that called the assessment area too narrow named, so Remove access or reverse the item follows for this CRA and Special-Purpose Programs file. 2. The population in model-reason-code mapping that does not match notices is adjacent only to a CRA PE that called the assessment area too narrow; Temporary compensating control is the honest Fair Lending call. 3. A bank with thin HMDA LAR quality already contained a CRA PE that called the assessment area too narrow before model-reason-code mapping that does not match notices arrived; no new CRA and Special-Purpose Programs path. 4. Provenance on model-reason-code mapping that does not match notices after a CRA PE that called the assessment area too narrow is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in model-reason-code mapping that does not match notices. 2. Check HMDA coding and underwriting policy against to pause a product. 3. Compare model-reason-code mapping that does not match notices to similarly situated files, second-review notes, and reason codes after a CRA PE that called the assessment area too narrow. 4. For this Fair Lending CRA and Special-Purpose Programs file, read model-reason-code mapping that does not match notices against a CRA PE that called the assessment area too narrow and write the one fact that would move to pause a product for fair-lending officer.

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 (model-reason-code mapping that does not match notices after a CRA PE that called the assessment area too narrow). Lead with the Fair Lending option model-reason-code mapping that does not match notices can support after a CRA PE that called the assessment area too narrow, then the two facts that force it, then the Monday action for fair-lending officer in a bank with thin HMDA LAR quality.