Assess whether to pause a product pending a lookback (7964e2)

SITUATION A board asking if the bank should settle a matched-pair study put geographic application and origination heat map in front of CRA strategist in a bank with thin HMDA LAR quality. This Fair Lending / Examination and Notices close is to pause a product from geographic application and origination heat map, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

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 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 geographic application and origination heat map 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 geographic application and origination heat map; 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 geographic application and origination heat map — reopen intake, do not close to pause a product. 4. Two facts in geographic application and origination heat map after a board asking if the bank should settle a matched-pair study conflict for CRA strategist; hold this Examination and Notices file.

ANALYSIS REQUIRED 1. Compare geographic application and origination heat map to similarly situated files, second-review notes, and reason codes after a board asking if the bank should settle a matched-pair study. 2. Flag any disparate-impact table CRA strategist cannot explain from geographic application and origination heat map. 3. Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend. 4. For this Fair Lending Examination and Notices file, read geographic application and origination heat map 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 / Examination and Notices packet (geographic application and origination heat map after a board asking if the bank should settle a matched-pair study). The follow-on Examination and Notices action is what CRA strategist does next: implement the option, assign an owner, and log the missing fact.