Assess whether to pause a product pending a lookback (ceac4b)

SITUATION Community-development lender is responsible for to pause a product in a bank, using thin HMDA LAR quality with small-business decline comparative file set as the only working extract. A CRA PE that called the assessment area too narrow is what reset the timeline for this Fair Lending Pricing and Credit Limits file.

DECISION Community-development lender in a bank with thin HMDA LAR quality 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 CRA PE that called the assessment area too narrow.

HYPOTHESES TO TEST 1. Small-business decline comparative file set reads as Remove access or reverse the item once a CRA PE that called the assessment area too narrow is lined up to the same Fair Lending population. 2. Small-business decline comparative file set is closer to Temporary compensating control after a CRA PE that called the assessment area too narrow; Remove access or reverse the item would over-claim this Pricing and Credit Limits extract. 3. Approve a documented exception is still live in small-business decline comparative file set for community-development lender in a bank with thin HMDA LAR quality. 4. Small-business decline comparative file set is missing the fact community-development lender needs after a CRA PE that called the assessment area too narrow; stop this Fair Lending close.

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 bank with thin HMDA LAR quality must defend. 3. Match the adverse-action language to the facts in small-business decline comparative file set. 4. For this Fair Lending Pricing and Credit Limits file, read small-business decline comparative file set against a CRA PE that called the assessment area too narrow 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 / Pricing and Credit Limits packet (small-business decline comparative file set after a CRA PE that called the assessment area too narrow). Lead with the Fair Lending option small-business decline comparative file set can support after a CRA PE that called the assessment area too narrow, then the two facts that force it, then the Monday action for community-development lender in a bank with thin HMDA LAR quality.

COMMAND RETURNS - Bottom-line Fair Lending option on to pause a product, then the evidence in small-business decline comparative file set, then the action for community-development lender - Hypothesis scorecard against small-business decline comparative file set: supported / rejected / untestable - Owner and next date for community-development lender in a bank with thin HMDA LAR quality - What changes to pause a product if a CRA PE that called the assessment area too narrow is later withdrawn