Assess whether to pause a product pending a lookback (48bf2e)

SITUATION Credit-card limit assignment disparity table arrived with a HMDA resubmission that still fails quality edits for adverse-action notice operations lead. That is a Fair Lending Redlining and HMDA Data decision on to pause a product in a lender expanding into majority-minority census tracts.

DECISION Adverse-action notice operations lead in a lender expanding into majority-minority census tracts 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 HMDA resubmission that still fails quality edits.

HYPOTHESES TO TEST 1. The population in credit-card limit assignment disparity table is the one a HMDA resubmission that still fails quality edits named, so Remove access or reverse the item follows for this Redlining and HMDA Data file. 2. The population in credit-card limit assignment disparity table is adjacent only to a HMDA resubmission that still fails quality edits; Temporary compensating control is the honest Fair Lending call. 3. A lender expanding into majority-minority census tracts already contained a HMDA resubmission that still fails quality edits before credit-card limit assignment disparity table arrived; no new Redlining and HMDA Data path. 4. Provenance on credit-card limit assignment disparity table after a HMDA resubmission that still fails quality edits is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

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 HMDA resubmission that still fails quality edits. 3. Flag any disparate-impact table adverse-action notice operations lead 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 HMDA resubmission that still fails quality edits 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 / Redlining and HMDA Data packet (credit-card limit assignment disparity table after a HMDA resubmission that still fails quality edits). Lead with the Fair Lending option credit-card limit assignment disparity table can support after a HMDA resubmission that still fails quality edits, then the two facts that force it, then the Monday action for adverse-action notice operations lead in a lender expanding into majority-minority census tracts.