Assess whether to pause a product pending a lookback (f68beb)

SITUATION After a CRA PE that called the assessment area too narrow, mortgage pricing residual by prohibited-basis group is what fair-lending officer can touch in an institution preparing for a redlining exam. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this Examination and Notices file.

DECISION Fair-lending officer in an institution preparing for a redlining exam 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 CRA PE that called the assessment area too narrow.

HYPOTHESES TO TEST 1. A CRA PE that called the assessment area too narrow is noise around an already-controlled Examination and Notices process in an institution preparing for a redlining exam, given mortgage pricing residual by prohibited-basis group. 2. A CRA PE that called the assessment area too narrow is the event in mortgage pricing residual by prohibited-basis group that forces Remove access or reverse the item for fair-lending officer under Fair Lending. 3. Mortgage pricing residual by prohibited-basis group shows a one-file miss after a CRA PE that called the assessment area too narrow, not a Examination and Notices program failure. 4. Mortgage pricing residual by prohibited-basis group cannot decide to pause a product yet after a CRA PE that called the assessment area too narrow; hold is the only Fair Lending close an institution preparing for a redlining exam can defend.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in mortgage pricing residual by prohibited-basis group. 2. Check HMDA coding and underwriting policy against to pause a product. 3. Compare mortgage pricing residual by prohibited-basis group 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 Examination and Notices file, read mortgage pricing residual by prohibited-basis group 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 / Examination and Notices packet (mortgage pricing residual by prohibited-basis group after a CRA PE that called the assessment area too narrow). The follow-on Examination and Notices action is what fair-lending officer does next: implement the option, assign an owner, and log the missing fact.

COMMAND RETURNS - Bottom-line Fair Lending option on to pause a product, then the evidence in mortgage pricing residual by prohibited-basis group, then the action for fair-lending officer - Hypothesis scorecard against mortgage pricing residual by prohibited-basis group: supported / rejected / untestable - Named option among Remove access or reverse the item, Temporary compensating control, Approve a documented exception and the fact that kills the others - Owner and next date for fair-lending officer in an institution preparing for a redlining exam