Assess whether to pause a product pending a lookback (b58694)

SITUATION Fair-lending officer in a bank with thin HMDA LAR quality has one working extract — appraisal-gap outcomes in majority-minority tracts — after an exception rate twice as high for one group after credit controls. Fair-lending officer in a bank with thin HMDA LAR quality has appraisal-gap outcomes in majority-minority tracts after an exception rate twice as high for one group after credit controls. If that extract cannot support to pause a product, the only defensible Fair Lending CRA and Special-Purpose Programs output is hold.

DECISION Fair-lending officer 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 an exception rate twice as high for one group after credit controls.

HYPOTHESES TO TEST 1. Appraisal-gap outcomes in majority-minority tracts 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. Appraisal-gap outcomes in majority-minority tracts 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 appraisal-gap outcomes in majority-minority tracts for fair-lending officer in a bank with thin HMDA LAR quality. 4. Appraisal-gap outcomes in majority-minority tracts is missing the fact fair-lending officer 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 appraisal-gap outcomes in majority-minority tracts 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 fair-lending officer cannot explain from appraisal-gap outcomes in majority-minority tracts. 4. For this Fair Lending CRA and Special-Purpose Programs file, read appraisal-gap outcomes in majority-minority tracts 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 fair-lending officer.

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 (appraisal-gap outcomes in majority-minority tracts after an exception rate twice as high for one group after credit controls). Lead with the Fair Lending option appraisal-gap outcomes in majority-minority tracts can support after an exception rate twice as high for one group after credit controls, then the two facts that force it, then the Monday action for fair-lending officer in a bank with thin HMDA LAR quality.