Assess whether to pause a product pending a lookback (f940f5)

SITUATION In a credit union rolling out a special-purpose credit program, HMDA LAR validity and quality edits is the evidence after a vendor score change with no disparate-impact test. HMDA data-quality manager has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending CRA and Special-Purpose Programs close using HMDA LAR validity and quality edits.

DECISION HMDA data-quality manager in a credit union rolling out a special-purpose credit program 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 vendor score change with no disparate-impact test.

HYPOTHESES TO TEST 1. A vendor score change with no disparate-impact test is noise around an already-controlled CRA and Special-Purpose Programs process in a credit union rolling out a special-purpose credit program, given HMDA LAR validity and quality edits. 2. A vendor score change with no disparate-impact test is the event in HMDA LAR validity and quality edits that forces Remove access or reverse the item for HMDA data-quality manager under Fair Lending. 3. HMDA LAR validity and quality edits shows a one-file miss after a vendor score change with no disparate-impact test, not a CRA and Special-Purpose Programs program failure. 4. HMDA LAR validity and quality edits cannot decide to pause a product yet after a vendor score change with no disparate-impact test; hold is the only Fair Lending close a credit union rolling out a special-purpose credit program can defend.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against to pause a product. 2. Compare HMDA LAR validity and quality edits to similarly situated files, second-review notes, and reason codes after a vendor score change with no disparate-impact test. 3. Flag any disparate-impact table HMDA data-quality manager cannot explain from HMDA LAR validity and quality edits. 4. For this Fair Lending CRA and Special-Purpose Programs file, read HMDA LAR validity and quality edits against a vendor score change with no disparate-impact test and write the one fact that would move to pause a product for HMDA data-quality manager.

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 vendor score change with no disparate-impact test). The follow-on CRA and Special-Purpose Programs action is what HMDA data-quality manager does next: implement the option, assign an owner, and log the missing fact.