Assess whether to pause a product pending a lookback (c4c46e)

SITUATION After a board asking if the bank should settle a matched-pair study, HMDA LAR validity and quality edits is what community-development lender can touch in an institution preparing for a redlining exam. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this CRA and Special-Purpose Programs file.

DECISION Community-development lender in an institution preparing for a redlining exam must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using HMDA LAR validity and quality edits after a board asking if the bank should settle a matched-pair study.

HYPOTHESES TO TEST 1. HMDA LAR validity and quality edits reads as Remove access or reverse the item once a board asking if the bank should settle a matched-pair study is lined up to the same Fair Lending population. 2. HMDA LAR validity and quality edits is closer to Temporary compensating control after a board asking if the bank should settle a matched-pair study; Remove access or reverse the item would over-claim this CRA and Special-Purpose Programs extract. 3. Approve a documented exception is still live in HMDA LAR validity and quality edits for community-development lender in an institution preparing for a redlining exam. 4. HMDA LAR validity and quality edits is missing the fact community-development lender needs after a board asking if the bank should settle a matched-pair study; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern an institution preparing for a redlining exam must defend. 2. Match the adverse-action language to the facts in HMDA LAR validity and quality edits. 3. Check HMDA coding and underwriting policy against to pause a product. 4. For this Fair Lending CRA and Special-Purpose Programs file, read HMDA LAR validity and quality edits 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 community-development lender.

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 (HMDA LAR validity and quality edits after a board asking if the bank should settle a matched-pair study). If HMDA LAR validity and quality edits cannot force a Fair Lending label under CRA and Special-Purpose Programs, stop. If HMDA LAR validity and quality edits after a board asking if the bank should settle a matched-pair study cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending CRA and Special-Purpose Programs close, community-development lender must do not infer a control or scheme beyond the transaction and entitlement evidence.