Assess whether to pause a product pending a lookback (1e0c8a)

SITUATION After a DOJ or CFPB monitor request for pricing files, mortgage pricing residual by prohibited-basis group is what HMDA data-quality manager can touch in a credit union rolling out a special-purpose credit program. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this CRA and Special-Purpose Programs file.

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 mortgage pricing residual by prohibited-basis group after a DOJ or CFPB monitor request for pricing files.

HYPOTHESES TO TEST 1. Mortgage pricing residual by prohibited-basis group reads as Remove access or reverse the item once a DOJ or CFPB monitor request for pricing files is lined up to the same Fair Lending population. 2. Mortgage pricing residual by prohibited-basis group is closer to Temporary compensating control after a DOJ or CFPB monitor request for pricing files; 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 mortgage pricing residual by prohibited-basis group for HMDA data-quality manager in a credit union rolling out a special-purpose credit program. 4. Mortgage pricing residual by prohibited-basis group is missing the fact HMDA data-quality manager needs after a DOJ or CFPB monitor request for pricing files; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Flag any disparate-impact table HMDA data-quality manager cannot explain from mortgage pricing residual by prohibited-basis group. 2. Test a documented exception versus a pattern a credit union rolling out a special-purpose credit program must defend. 3. Match the adverse-action language to the facts in mortgage pricing residual by prohibited-basis group. 4. For this Fair Lending CRA and Special-Purpose Programs file, read mortgage pricing residual by prohibited-basis group against a DOJ or CFPB monitor request for pricing files 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 (mortgage pricing residual by prohibited-basis group after a DOJ or CFPB monitor request for pricing files). 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.

COMMAND RETURNS - Bottom-line Fair Lending option on to pause a product, then the evidence in mortgage pricing residual by prohibited-basis group, then the action for HMDA data-quality manager - Hypothesis scorecard against mortgage pricing residual by prohibited-basis group: supported / rejected / untestable - CRA and Special-Purpose Programs finding in mortgage pricing residual by prohibited-basis group that a second reviewer can re-perform - Missing page in mortgage pricing residual by prohibited-basis group after a DOJ or CFPB monitor request for pricing files, if any