Assess whether to pause a product pending a lookback (64fd13)

SITUATION Exam-response coordinator in a bank with thin HMDA LAR quality has one working extract — geographic application and origination heat map — after a DOJ or CFPB monitor request for pricing files. Exam-response coordinator in a bank with thin HMDA LAR quality has geographic application and origination heat map after a DOJ or CFPB monitor request for pricing files. If that extract cannot support to pause a product, the only defensible Fair Lending Redlining and HMDA Data output is hold.

DECISION Exam-response coordinator 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 DOJ or CFPB monitor request for pricing files.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; geographic application and origination heat map already has the discriminator after a DOJ or CFPB monitor request for pricing files. 2. Keep Temporary compensating control in force until geographic application and origination heat map is completed after a DOJ or CFPB monitor request for pricing files for exam-response coordinator. 3. Treat geographic application and origination heat map as Approve a documented exception because both readings appear after a DOJ or CFPB monitor request for pricing files. 4. Refuse a Fair Lending close: exam-response coordinator does not have the decision to pause a product turns on in geographic application and origination heat map.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against to pause a product. 2. Compare geographic application and origination heat map to similarly situated files, second-review notes, and reason codes after a DOJ or CFPB monitor request for pricing files. 3. Flag any disparate-impact table exam-response coordinator cannot explain from geographic application and origination heat map. 4. For this Fair Lending Redlining and HMDA Data file, read geographic application and origination heat map against a DOJ or CFPB monitor request for pricing files and write the one fact that would move to pause a product for exam-response coordinator.

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 (geographic application and origination heat map after a DOJ or CFPB monitor request for pricing files). If geographic application and origination heat map cannot force a Fair Lending label under Redlining and HMDA Data, stop. If geographic application and origination heat map after a DOJ or CFPB monitor request for pricing files cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending Redlining and HMDA Data close, exam-response coordinator must do not infer a control or scheme beyond the transaction and entitlement evidence.