Assess whether to pause a product pending a lookback (7e1d7a)

SITUATION Small-business decline comparative file set arrived with a SPCP that originated almost no loans to the intended class for HMDA data-quality manager. That is a Fair Lending Redlining and HMDA Data decision on to pause a product in a credit-card issuer changing line-assignment logic.

DECISION HMDA data-quality manager in a credit-card issuer changing line-assignment logic 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 SPCP that originated almost no loans to the intended class.

HYPOTHESES TO TEST 1. The population in small-business decline comparative file set is the one a SPCP that originated almost no loans to the intended class named, so Remove access or reverse the item follows for this Redlining and HMDA Data file. 2. The population in small-business decline comparative file set is adjacent only to a SPCP that originated almost no loans to the intended class; Temporary compensating control is the honest Fair Lending call. 3. A credit-card issuer changing line-assignment logic already contained a SPCP that originated almost no loans to the intended class before small-business decline comparative file set arrived; no new Redlining and HMDA Data path. 4. Provenance on small-business decline comparative file set after a SPCP that originated almost no loans to the intended class is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern a credit-card issuer changing line-assignment logic must defend. 2. Match the adverse-action language to the facts in small-business decline comparative file set. 3. Check HMDA coding and underwriting policy against to pause a product. 4. For this Fair Lending Redlining and HMDA Data file, read small-business decline comparative file set against a SPCP that originated almost no loans to the intended class and write the one fact that would move to pause a product for HMDA data-quality manager.

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 (small-business decline comparative file set after a SPCP that originated almost no loans to the intended class). The follow-on Redlining and HMDA Data action is what HMDA data-quality manager 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 small-business decline comparative file set, then the action for HMDA data-quality manager - Hypothesis scorecard against small-business decline comparative file set: supported / rejected / untestable - What changes to pause a product if a SPCP that originated almost no loans to the intended class is later withdrawn - Named option among Remove access or reverse the item, Temporary compensating control, Approve a documented exception and the fact that kills the others