Assess whether to pause a product pending a lookback (f3b7ec)

SITUATION A live Fair Lending Redlining and HMDA Data file in an institution preparing for a redlining exam now turns on credit-card limit assignment disparity table after a board asking if the bank should settle a matched-pair study. CRA strategist should state what that extract proves for whether to pause a product pending a lookback.

DECISION CRA strategist in an institution preparing for a redlining exam must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using credit-card limit assignment disparity table after a board asking if the bank should settle a matched-pair study.

HYPOTHESES TO TEST 1. CRA strategist can defend Remove access or reverse the item from credit-card limit assignment disparity table after a board asking if the bank should settle a matched-pair study in a Fair Lending challenge. 2. CRA strategist cannot defend Remove access or reverse the item from credit-card limit assignment disparity table; Temporary compensating control is what the extract actually supports after a board asking if the bank should settle a matched-pair study. 3. A board asking if the bank should settle a matched-pair study never reached the population in credit-card limit assignment disparity table — reopen intake, do not close to pause a product. 4. Two facts in credit-card limit assignment disparity table after a board asking if the bank should settle a matched-pair study conflict for CRA strategist; hold this Redlining and HMDA Data file.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against to pause a product. 2. Compare credit-card limit assignment disparity table to similarly situated files, second-review notes, and reason codes after a board asking if the bank should settle a matched-pair study. 3. Flag any disparate-impact table CRA strategist cannot explain from credit-card limit assignment disparity table. 4. For this Fair Lending Redlining and HMDA Data file, read credit-card limit assignment disparity table against a board asking if the bank should settle a matched-pair study 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 / Redlining and HMDA Data packet (credit-card limit assignment disparity table after a board asking if the bank should settle a matched-pair study). Lead with the Fair Lending option credit-card limit assignment disparity table can support after a board asking if the bank should settle a matched-pair study, then the two facts that force it, then the Monday action for CRA strategist in an institution preparing for a redlining exam.