Assess whether to pause a product pending a lookback (8a0127)

SITUATION Fair-lending officer received adverse-action notice principal-reason sample after a board asking if the bank should settle a matched-pair study in an institution preparing for a redlining exam. Remove access or reverse the item or Temporary compensating control must follow from that extract if the file can settle whether to pause a product pending a lookback.

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 adverse-action notice principal-reason sample after a board asking if the bank should settle a matched-pair study.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; adverse-action notice principal-reason sample already has the discriminator after a board asking if the bank should settle a matched-pair study. 2. Keep Temporary compensating control in force until adverse-action notice principal-reason sample is completed after a board asking if the bank should settle a matched-pair study for fair-lending officer. 3. Treat adverse-action notice principal-reason sample as Approve a documented exception because both readings appear after a board asking if the bank should settle a matched-pair study. 4. Refuse a Fair Lending close: fair-lending officer does not have the decision to pause a product turns on in adverse-action notice principal-reason sample.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in adverse-action notice principal-reason sample. 2. Check HMDA coding and underwriting policy against to pause a product. 3. Compare adverse-action notice principal-reason sample to similarly situated files, second-review notes, and reason codes after a board asking if the bank should settle a matched-pair study. 4. For this Fair Lending Examination and Notices file, read adverse-action notice principal-reason sample against a board asking if the bank should settle a matched-pair study 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 (adverse-action notice principal-reason sample after a board asking if the bank should settle a matched-pair study). Lead with the Fair Lending option adverse-action notice principal-reason sample can support after a board asking if the bank should settle a matched-pair study, then the two facts that force it, then the Monday action for fair-lending officer in an institution preparing for a redlining exam.