Assess whether to pause a product pending a lookback (f75ebe)

SITUATION CRA and Special-Purpose Programs work in an institution preparing for a redlining exam now turns on to pause a product because a notice that cites 'other' as the principal reason 40% of the time put small-business decline comparative file set in play. CRA and Special-Purpose Programs work in an institution preparing for a redlining exam now turns on to pause a product because a notice that cites 'other' as the principal reason 40% of the time put small-business decline comparative file set in play; community-development lender should say what small-business decline comparative file set proves for Fair Lending.

DECISION Community-development lender 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 small-business decline comparative file set after a notice that cites 'other' as the principal reason 40% of the time.

HYPOTHESES TO TEST 1. Small-business decline comparative file set reads as Remove access or reverse the item once a notice that cites 'other' as the principal reason 40% of the time is lined up to the same Fair Lending population. 2. Small-business decline comparative file set is closer to Temporary compensating control after a notice that cites 'other' as the principal reason 40% of the time; Remove access or reverse the item would over-claim this CRA and Special-Purpose Programs extract. 3. Approve a documented exception is still live in small-business decline comparative file set for community-development lender in an institution preparing for a redlining exam. 4. Small-business decline comparative file set is missing the fact community-development lender needs after a notice that cites 'other' as the principal reason 40% of the time; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against to pause a product. 2. Compare small-business decline comparative file set to similarly situated files, second-review notes, and reason codes after a notice that cites 'other' as the principal reason 40% of the time. 3. Flag any disparate-impact table community-development lender cannot explain from small-business decline comparative file set. 4. For this Fair Lending CRA and Special-Purpose Programs file, read small-business decline comparative file set against a notice that cites 'other' as the principal reason 40% of the time 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 / CRA and Special-Purpose Programs packet (small-business decline comparative file set after a notice that cites 'other' as the principal reason 40% of the time). If small-business decline comparative file set cannot force a Fair Lending label under CRA and Special-Purpose Programs, stop. If small-business decline comparative file set after a notice that cites 'other' as the principal reason 40% of the time cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending CRA and Special-Purpose Programs close, community-development lender must do not infer a control or scheme beyond the transaction and entitlement evidence.