Assess whether to pause a product pending a lookback (dce927)

SITUATION A HMDA resubmission that still fails quality edits put mortgage pricing residual by prohibited-basis group in front of exam-response coordinator in a bank with thin HMDA LAR quality. This Fair Lending / Redlining and HMDA Data close is to pause a product from mortgage pricing residual by prohibited-basis group, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

DECISION Exam-response coordinator 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 mortgage pricing residual by prohibited-basis group after a HMDA resubmission that still fails quality edits.

HYPOTHESES TO TEST 1. Mortgage pricing residual by prohibited-basis group reads as Remove access or reverse the item once a HMDA resubmission that still fails quality edits is lined up to the same Fair Lending population. 2. Mortgage pricing residual by prohibited-basis group is closer to Temporary compensating control after a HMDA resubmission that still fails quality edits; Remove access or reverse the item would over-claim this Redlining and HMDA Data extract. 3. Approve a documented exception is still live in mortgage pricing residual by prohibited-basis group for exam-response coordinator in a bank with thin HMDA LAR quality. 4. Mortgage pricing residual by prohibited-basis group is missing the fact exam-response coordinator needs after a HMDA resubmission that still fails quality edits; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Compare mortgage pricing residual by prohibited-basis group to similarly situated files, second-review notes, and reason codes after a HMDA resubmission that still fails quality edits. 2. Flag any disparate-impact table exam-response coordinator cannot explain from mortgage pricing residual by prohibited-basis group. 3. Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend. 4. For this Fair Lending Redlining and HMDA Data file, read mortgage pricing residual by prohibited-basis group against a HMDA resubmission that still fails quality edits and write the one fact that would move to pause a product for exam-response coordinator.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Redlining and HMDA Data packet (mortgage pricing residual by prohibited-basis group after a HMDA resubmission that still fails quality edits). The follow-on Redlining and HMDA Data action is what exam-response coordinator does next: implement the option, assign an owner, and log the missing fact.