Assess whether to pause a product pending a lookback (170a0d)

SITUATION The CRA and Special-Purpose Programs working file is model-reason-code mapping that does not match notices after a HMDA resubmission that still fails quality edits. Second-review underwriter in a lender expanding into majority-minority census tracts must name Remove access or reverse the item or Temporary compensating control for this Fair Lending file. Second-review underwriter in a lender expanding into majority-minority census tracts has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending CRA and Special-Purpose Programs file.

DECISION Second-review underwriter in a lender expanding into majority-minority census tracts must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using model-reason-code mapping that does not match notices after a HMDA resubmission that still fails quality edits.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; model-reason-code mapping that does not match notices already has the discriminator after a HMDA resubmission that still fails quality edits. 2. Keep Temporary compensating control in force until model-reason-code mapping that does not match notices is completed after a HMDA resubmission that still fails quality edits for second-review underwriter. 3. Treat model-reason-code mapping that does not match notices as Approve a documented exception because both readings appear after a HMDA resubmission that still fails quality edits. 4. Refuse a Fair Lending close: second-review underwriter does not have the decision to pause a product turns on in model-reason-code mapping that does not match notices.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in model-reason-code mapping that does not match notices. 2. Check HMDA coding and underwriting policy against to pause a product. 3. Compare model-reason-code mapping that does not match notices to similarly situated files, second-review notes, and reason codes after a HMDA resubmission that still fails quality edits. 4. For this Fair Lending CRA and Special-Purpose Programs file, read model-reason-code mapping that does not match notices against a HMDA resubmission that still fails quality edits and write the one fact that would move to pause a product for second-review underwriter.

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 (model-reason-code mapping that does not match notices after a HMDA resubmission that still fails quality edits). If model-reason-code mapping that does not match notices cannot force a Fair Lending label under CRA and Special-Purpose Programs, stop. If model-reason-code mapping that does not match notices after a HMDA resubmission that still fails quality edits cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending CRA and Special-Purpose Programs close, second-review underwriter must do not infer a control or scheme beyond the transaction and entitlement evidence.