Assess whether to pause a product pending a lookback (e10b5a)

SITUATION An exception rate twice as high for one group after credit controls put adverse-action notice principal-reason sample in front of CRA strategist in a mortgage company after a pricing-regression spike. This Fair Lending / CRA and Special-Purpose Programs close is to pause a product from adverse-action notice principal-reason sample, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

DECISION CRA strategist in a mortgage company after a pricing-regression spike must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using adverse-action notice principal-reason sample after an exception rate twice as high for one group after credit controls.

HYPOTHESES TO TEST 1. Adverse-action notice principal-reason sample reads as Remove access or reverse the item once an exception rate twice as high for one group after credit controls is lined up to the same Fair Lending population. 2. Adverse-action notice principal-reason sample is closer to Temporary compensating control after an exception rate twice as high for one group after credit controls; 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 adverse-action notice principal-reason sample for CRA strategist in a mortgage company after a pricing-regression spike. 4. Adverse-action notice principal-reason sample is missing the fact CRA strategist needs after an exception rate twice as high for one group after credit controls; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against to pause a product. 2. Compare adverse-action notice principal-reason sample to similarly situated files, second-review notes, and reason codes after an exception rate twice as high for one group after credit controls. 3. Flag any disparate-impact table CRA strategist cannot explain from adverse-action notice principal-reason sample. 4. For this Fair Lending CRA and Special-Purpose Programs file, read adverse-action notice principal-reason sample against an exception rate twice as high for one group after credit controls and write the one fact that would move to pause a product for CRA strategist.

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 (adverse-action notice principal-reason sample after an exception rate twice as high for one group after credit controls). The follow-on CRA and Special-Purpose Programs action is what CRA strategist does next: implement the option, assign an owner, and log the missing fact.