Assess whether to pause a product pending a lookback (182401)

SITUATION CRA assessment-area versus lending footprint arrived with a CRA PE that called the assessment area too narrow. CRA strategist in a mortgage company after a pricing-regression spike still has an evidence gap on whether to pause a product pending a lookback.

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 CRA assessment-area versus lending footprint after a CRA PE that called the assessment area too narrow.

HYPOTHESES TO TEST 1. CRA strategist can defend Remove access or reverse the item from CRA assessment-area versus lending footprint after a CRA PE that called the assessment area too narrow in a Fair Lending challenge. 2. CRA strategist cannot defend Remove access or reverse the item from CRA assessment-area versus lending footprint; Temporary compensating control is what the extract actually supports after a CRA PE that called the assessment area too narrow. 3. A CRA PE that called the assessment area too narrow never reached the population in CRA assessment-area versus lending footprint — reopen intake, do not close to pause a product. 4. Two facts in CRA assessment-area versus lending footprint after a CRA PE that called the assessment area too narrow conflict for CRA strategist; hold this CRA and Special-Purpose Programs file.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against to pause a product. 2. Compare CRA assessment-area versus lending footprint to similarly situated files, second-review notes, and reason codes after a CRA PE that called the assessment area too narrow. 3. Flag any disparate-impact table CRA strategist cannot explain from CRA assessment-area versus lending footprint. 4. For this Fair Lending CRA and Special-Purpose Programs file, read CRA assessment-area versus lending footprint against a CRA PE that called the assessment area too narrow 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 (CRA assessment-area versus lending footprint after a CRA PE that called the assessment area too narrow). Lead with the Fair Lending option CRA assessment-area versus lending footprint can support after a CRA PE that called the assessment area too narrow, then the two facts that force it, then the Monday action for CRA strategist in a mortgage company after a pricing-regression spike.

COMMAND RETURNS - Bottom-line Fair Lending option on to pause a product, then the evidence in CRA assessment-area versus lending footprint, then the action for CRA strategist - Hypothesis scorecard against CRA assessment-area versus lending footprint: 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 CRA strategist in a mortgage company after a pricing-regression spike