Assess whether to pause a product pending a lookback (b360ef)

SITUATION After a notice that cites 'other' as the principal reason 40% of the time, appraisal-gap outcomes in majority-minority tracts is what adverse-action notice operations lead can touch in a small-business desk using a new vendor score. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this CRA and Special-Purpose Programs file.

DECISION Adverse-action notice operations lead in a small-business desk using a new vendor score 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 notice that cites 'other' as the principal reason 40% of the time.

HYPOTHESES TO TEST 1. Appraisal-gap outcomes in majority-minority tracts reads as Remove access or reverse the item once a notice that cites 'other' as the principal reason 40% of the time is lined up to the same Fair Lending population. 2. Appraisal-gap outcomes in majority-minority tracts is closer to Temporary compensating control after a notice that cites 'other' as the principal reason 40% of the time; 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 adverse-action notice operations lead in a small-business desk using a new vendor score. 4. Appraisal-gap outcomes in majority-minority tracts is missing the fact adverse-action notice operations lead needs after a notice that cites 'other' as the principal reason 40% of the time; 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 a notice that cites 'other' as the principal reason 40% of the time. 3. Flag any disparate-impact table adverse-action notice operations lead 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 a notice that cites 'other' as the principal reason 40% of the time and write the one fact that would move to pause a product for adverse-action notice operations lead.

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 a notice that cites 'other' as the principal reason 40% of the time). Lead with the Fair Lending option appraisal-gap outcomes in majority-minority tracts can support after a notice that cites 'other' as the principal reason 40% of the time, then the two facts that force it, then the Monday action for adverse-action notice operations lead in a small-business desk using a new vendor score.