Assess whether to pause a product pending a lookback (1e45cb)

SITUATION A board asking if the bank should settle a matched-pair study put small-business decline comparative file set in front of community-development lender in a mortgage company after a pricing-regression spike. This Fair Lending / Redlining and HMDA Data close is to pause a product from small-business decline comparative file set, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

DECISION Community-development lender in a mortgage company after a pricing-regression spike must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using small-business decline comparative file set after a board asking if the bank should settle a matched-pair study.

HYPOTHESES TO TEST 1. The population in small-business decline comparative file set is the one a board asking if the bank should settle a matched-pair study named, so Remove access or reverse the item follows for this Redlining and HMDA Data file. 2. The population in small-business decline comparative file set is adjacent only to a board asking if the bank should settle a matched-pair study; Temporary compensating control is the honest Fair Lending call. 3. A mortgage company after a pricing-regression spike already contained a board asking if the bank should settle a matched-pair study before small-business decline comparative file set arrived; no new Redlining and HMDA Data path. 4. Provenance on small-business decline comparative file set after a board asking if the bank should settle a matched-pair study is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

ANALYSIS REQUIRED 1. Flag any disparate-impact table community-development lender cannot explain from small-business decline comparative file set. 2. Test a documented exception versus a pattern a mortgage company after a pricing-regression spike must defend. 3. Match the adverse-action language to the facts in small-business decline comparative file set. 4. For this Fair Lending Redlining and HMDA Data file, read small-business decline comparative file set 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 / Redlining and HMDA Data packet (small-business decline comparative file set after a board asking if the bank should settle a matched-pair study). The follow-on Redlining and HMDA Data action is what community-development lender does next: implement the option, assign an owner, and log the missing fact.