Assess whether to pause a product pending a lookback from small-business

SITUATION A bank with thin HMDA LAR quality cannot treat an underwriter chat that used coded language as incidental context on small-business decline comparative file set. Community-development lender must close to pause a product from that extract under Fair Lending / Pricing and Credit Limits.

DECISION Community-development lender 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 small-business decline comparative file set after an underwriter chat that used coded language.

HYPOTHESES TO TEST 1. Community-development lender can defend Remove access or reverse the item from small-business decline comparative file set after an underwriter chat that used coded language in a Fair Lending challenge. 2. Community-development lender cannot defend Remove access or reverse the item from small-business decline comparative file set; Temporary compensating control is what the extract actually supports after an underwriter chat that used coded language. 3. An underwriter chat that used coded language never reached the population in small-business decline comparative file set — reopen intake, do not close to pause a product. 4. Two facts in small-business decline comparative file set after an underwriter chat that used coded language conflict for community-development lender; hold this Pricing and Credit Limits file.

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 an underwriter chat that used coded language. 3. Flag any disparate-impact table community-development lender cannot explain from small-business decline comparative file set. 4. For this Fair Lending Pricing and Credit Limits file, read small-business decline comparative file set against an underwriter chat that used coded language 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 / Pricing and Credit Limits packet (small-business decline comparative file set after an underwriter chat that used coded language). If small-business decline comparative file set cannot force a Fair Lending label under Pricing and Credit Limits, stop. Do not invent missing evidence a bank with thin HMDA LAR quality does not have.

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 community-development lender - Hypothesis scorecard against small-business decline comparative file set: supported / rejected / untestable - Pricing and Credit Limits finding in small-business decline comparative file set that a second reviewer can re-perform - Missing page in small-business decline comparative file set after an underwriter chat that used coded language, if any