Assess whether to pause a product pending a lookback from appraisal-gap

SITUATION Community-development lender is responsible for to pause a product in a bank, using thin HMDA LAR quality with appraisal-gap outcomes in majority-minority tracts as the only working extract. A branch that stopped taking applications in one ZIP is what reset the timeline for this Fair Lending Pricing and Credit Limits file.

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 appraisal-gap outcomes in majority-minority tracts after a branch that stopped taking applications in one ZIP.

HYPOTHESES TO TEST 1. A branch that stopped taking applications in one ZIP is noise around an already-controlled Pricing and Credit Limits process in a bank with thin HMDA LAR quality, given appraisal-gap outcomes in majority-minority tracts. 2. A branch that stopped taking applications in one ZIP is the event in appraisal-gap outcomes in majority-minority tracts that forces Remove access or reverse the item for community-development lender under Fair Lending. 3. Appraisal-gap outcomes in majority-minority tracts shows a one-file miss after a branch that stopped taking applications in one ZIP, not a Pricing and Credit Limits program failure. 4. Appraisal-gap outcomes in majority-minority tracts cannot decide to pause a product yet after a branch that stopped taking applications in one ZIP; hold is the only Fair Lending close a bank with thin HMDA LAR quality can defend.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in appraisal-gap outcomes in majority-minority tracts. 2. Check HMDA coding and underwriting policy against to pause a product. 3. Compare appraisal-gap outcomes in majority-minority tracts to similarly situated files, second-review notes, and reason codes after a branch that stopped taking applications in one ZIP. 4. For this Fair Lending Pricing and Credit Limits file, read appraisal-gap outcomes in majority-minority tracts against a branch that stopped taking applications in one ZIP 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 (appraisal-gap outcomes in majority-minority tracts after a branch that stopped taking applications in one ZIP). The follow-on Pricing and Credit Limits action is what community-development lender 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 appraisal-gap outcomes in majority-minority tracts, then the action for community-development lender - Hypothesis scorecard against appraisal-gap outcomes in majority-minority tracts: supported / rejected / untestable - Named option among Remove access or reverse the item, Temporary compensating control, Approve a documented exception and the fact that kills the others - Owner and next date for community-development lender in a bank with thin HMDA LAR quality