Assess whether to pause a product pending a lookback (f94acd)

SITUATION In a lender expanding into majority-minority census tracts, credit-card limit assignment disparity table is the evidence after a notice that cites 'other' as the principal reason 40% of the time. Second-review underwriter has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending CRA and Special-Purpose Programs close using credit-card limit assignment disparity table.

DECISION Second-review underwriter 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 notice that cites 'other' as the principal reason 40% of the time.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; credit-card limit assignment disparity table already has the discriminator after a notice that cites 'other' as the principal reason 40% of the time. 2. Keep Temporary compensating control in force until credit-card limit assignment disparity table is completed after a notice that cites 'other' as the principal reason 40% of the time for second-review underwriter. 3. Treat credit-card limit assignment disparity table as Approve a documented exception because both readings appear after a notice that cites 'other' as the principal reason 40% of the time. 4. Refuse a Fair Lending close: second-review underwriter does not have the decision to pause a product turns on in credit-card limit assignment disparity table.

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 notice that cites 'other' as the principal reason 40% of the time. 3. Flag any disparate-impact table second-review underwriter cannot explain from credit-card limit assignment disparity table. 4. For this Fair Lending CRA and Special-Purpose Programs file, read credit-card limit assignment disparity table against a notice that cites 'other' as the principal reason 40% of the time 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 / CRA and Special-Purpose Programs packet (credit-card limit assignment disparity table after a notice that cites 'other' as the principal reason 40% of the time). The follow-on CRA and Special-Purpose Programs action is what second-review underwriter does next: implement the option, assign an owner, and log the missing fact.