Assess whether to pause a product pending a lookback (9cfe94)

SITUATION Second-review underwriter in a credit union rolling out a special-purpose credit program has one working extract — credit-card limit assignment disparity table — after a CRA PE that called the assessment area too narrow. If credit-card limit assignment disparity table cannot support to pause a product, the only defensible Fair Lending output is hold.

DECISION Second-review underwriter in a credit union rolling out a special-purpose credit program 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 CRA PE that called the assessment area too narrow.

HYPOTHESES TO TEST 1. Second-review underwriter can defend Remove access or reverse the item from credit-card limit assignment disparity table after a CRA PE that called the assessment area too narrow in a Fair Lending challenge. 2. Second-review underwriter 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 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 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 CRA PE that called the assessment area too narrow conflict for second-review underwriter; hold this Examination and Notices file.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in credit-card limit assignment disparity table. 2. Check HMDA coding and underwriting policy against to pause a product. 3. Compare credit-card limit assignment disparity table to similarly situated files, second-review notes, and reason codes after a CRA PE that called the assessment area too narrow. 4. For this Fair Lending Examination and Notices file, read credit-card limit assignment disparity table against a CRA PE that called the assessment area too narrow and write the one fact that would move to pause a product for second-review underwriter.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Examination and Notices packet (credit-card limit assignment disparity table after a CRA PE that called the assessment area too narrow). Lead with the Fair Lending option credit-card limit assignment disparity table 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 second-review underwriter in a credit union rolling out a special-purpose credit program.