Assess whether to pause a product pending a lookback (195a6c)

SITUATION In a credit-card issuer changing line-assignment logic, CRA assessment-area versus lending footprint is the evidence after a HMDA resubmission that still fails quality edits. HMDA data-quality manager has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending Redlining and HMDA Data close using CRA assessment-area versus lending footprint.

DECISION HMDA data-quality manager in a credit-card issuer changing line-assignment logic 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 HMDA resubmission that still fails quality edits.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; CRA assessment-area versus lending footprint already has the discriminator after a HMDA resubmission that still fails quality edits. 2. Keep Temporary compensating control in force until CRA assessment-area versus lending footprint is completed after a HMDA resubmission that still fails quality edits for HMDA data-quality manager. 3. Treat CRA assessment-area versus lending footprint as Approve a documented exception because both readings appear after a HMDA resubmission that still fails quality edits. 4. Refuse a Fair Lending close: HMDA data-quality manager does not have the decision to pause a product turns on in CRA assessment-area versus lending footprint.

ANALYSIS REQUIRED 1. Flag any disparate-impact table HMDA data-quality manager cannot explain from CRA assessment-area versus lending footprint. 2. Test a documented exception versus a pattern a credit-card issuer changing line-assignment logic must defend. 3. Match the adverse-action language to the facts in CRA assessment-area versus lending footprint. 4. For this Fair Lending Redlining and HMDA Data file, read CRA assessment-area versus lending footprint against a HMDA resubmission that still fails quality edits and write the one fact that would move to pause a product for HMDA data-quality manager.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Redlining and HMDA Data packet (CRA assessment-area versus lending footprint after a HMDA resubmission that still fails quality edits). If CRA assessment-area versus lending footprint cannot force a Fair Lending label under Redlining and HMDA Data, stop. If CRA assessment-area versus lending footprint after a HMDA resubmission that still fails quality edits cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending Redlining and HMDA Data close, HMDA data-quality manager must do not infer a control or scheme beyond the transaction and entitlement evidence.