Assess whether to pause a product pending a lookback (b7e920)

SITUATION Examination and Notices work in a bank with thin HMDA LAR quality now turns on to pause a product because a CRA PE that called the assessment area too narrow put geographic application and origination heat map in play. Examination and Notices work in a bank with thin HMDA LAR quality now turns on to pause a product because a CRA PE that called the assessment area too narrow put geographic application and origination heat map in play; CRA strategist should say what geographic application and origination heat map proves for Fair Lending.

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 CRA PE that called the assessment area too narrow.

HYPOTHESES TO TEST 1. The population in geographic application and origination heat map is the one a CRA PE that called the assessment area too narrow named, so Remove access or reverse the item follows for this Examination and Notices file. 2. The population in geographic application and origination heat map is adjacent only to a CRA PE that called the assessment area too narrow; Temporary compensating control is the honest Fair Lending call. 3. A bank with thin HMDA LAR quality already contained a CRA PE that called the assessment area too narrow before geographic application and origination heat map arrived; no new Examination and Notices path. 4. Provenance on geographic application and origination heat map after a CRA PE that called the assessment area too narrow is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend. 2. Match the adverse-action language to the facts in geographic application and origination heat map. 3. Check HMDA coding and underwriting policy against to pause a product. 4. For this Fair Lending Examination and Notices file, read geographic application and origination heat map against a CRA PE that called the assessment area too narrow 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 CRA PE that called the assessment area too narrow). The follow-on Examination and Notices action is what CRA strategist does next: implement the option, assign an owner, and log the missing fact.