Assess whether to pause a product pending a lookback (313a33)

SITUATION In a credit-card issuer changing line-assignment logic, mortgage pricing residual by prohibited-basis group is the evidence after an exception rate twice as high for one group after credit controls. HMDA data-quality manager has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending Redlining and HMDA Data close using mortgage pricing residual by prohibited-basis group.

DECISION HMDA data-quality manager in a credit-card issuer changing line-assignment logic 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 an exception rate twice as high for one group after credit controls.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; mortgage pricing residual by prohibited-basis group already has the discriminator after an exception rate twice as high for one group after credit controls. 2. Keep Temporary compensating control in force until mortgage pricing residual by prohibited-basis group is completed after an exception rate twice as high for one group after credit controls for HMDA data-quality manager. 3. Treat mortgage pricing residual by prohibited-basis group as Approve a documented exception because both readings appear after an exception rate twice as high for one group after credit controls. 4. Refuse a Fair Lending close: HMDA data-quality manager does not have the decision to pause a product turns on in mortgage pricing residual by prohibited-basis group.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in mortgage pricing residual by prohibited-basis group. 2. Check HMDA coding and underwriting policy against to pause a product. 3. Compare mortgage pricing residual by prohibited-basis group to similarly situated files, second-review notes, and reason codes after an exception rate twice as high for one group after credit controls. 4. For this Fair Lending Redlining and HMDA Data file, read mortgage pricing residual by prohibited-basis group against an exception rate twice as high for one group after credit controls 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 / Redlining and HMDA Data packet (mortgage pricing residual by prohibited-basis group after an exception rate twice as high for one group after credit controls). The follow-on Redlining and HMDA Data action is what HMDA data-quality manager does next: implement the option, assign an owner, and log the missing fact.