Assess whether to pause a product pending a lookback (a42cae)

SITUATION CRA strategist received geographic application and origination heat map after a community complaint about appraisal gaps in a bank with thin HMDA LAR quality. Remove access or reverse the item or Temporary compensating control must follow from that extract if the file can settle whether to pause a product pending a lookback.

DECISION CRA strategist in a bank with thin HMDA LAR quality must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using geographic application and origination heat map after a community complaint about appraisal gaps.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; geographic application and origination heat map already has the discriminator after a community complaint about appraisal gaps. 2. Keep Temporary compensating control in force until geographic application and origination heat map is completed after a community complaint about appraisal gaps for CRA strategist. 3. Treat geographic application and origination heat map as Approve a documented exception because both readings appear after a community complaint about appraisal gaps. 4. Refuse a Fair Lending close: CRA strategist does not have the decision to pause a product turns on in geographic application and origination heat map.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in geographic application and origination heat map. 2. Check HMDA coding and underwriting policy against to pause a product. 3. Compare geographic application and origination heat map to similarly situated files, second-review notes, and reason codes after a community complaint about appraisal gaps. 4. For this Fair Lending Examination and Notices file, read geographic application and origination heat map against a community complaint about appraisal gaps 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 / Examination and Notices packet (geographic application and origination heat map after a community complaint about appraisal gaps). Lead with the Fair Lending option geographic application and origination heat map can support after a community complaint about appraisal gaps, then the two facts that force it, then the Monday action for CRA strategist in a bank with thin HMDA LAR quality.

COMMAND RETURNS - Bottom-line Fair Lending option on to pause a product, then the evidence in geographic application and origination heat map, then the action for CRA strategist - Hypothesis scorecard against geographic application and origination heat map: supported / rejected / untestable - Examination and Notices finding in geographic application and origination heat map that a second reviewer can re-perform - Missing page in geographic application and origination heat map after a community complaint about appraisal gaps, if any