Assess whether to pause a product pending a lookback (7aa99c)

SITUATION A lender expanding into majority-minority census tracts cannot treat a board asking if the bank should settle a matched-pair study as incidental context on SPCP written plan versus actual originations. Second-review underwriter must close to pause a product from that extract under Fair Lending / CRA and Special-Purpose Programs.

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 SPCP written plan versus actual originations after a board asking if the bank should settle a matched-pair study.

HYPOTHESES TO TEST 1. The population in SPCP written plan versus actual originations 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 CRA and Special-Purpose Programs file. 2. The population in SPCP written plan versus actual originations 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 lender expanding into majority-minority census tracts already contained a board asking if the bank should settle a matched-pair study before SPCP written plan versus actual originations arrived; no new CRA and Special-Purpose Programs path. 4. Provenance on SPCP written plan versus actual originations 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. Check HMDA coding and underwriting policy against to pause a product. 2. Compare SPCP written plan versus actual originations to similarly situated files, second-review notes, and reason codes after a board asking if the bank should settle a matched-pair study. 3. Flag any disparate-impact table second-review underwriter cannot explain from SPCP written plan versus actual originations. 4. For this Fair Lending CRA and Special-Purpose Programs file, read SPCP written plan versus actual originations 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 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 (SPCP written plan versus actual originations after a board asking if the bank should settle a matched-pair study). Lead with the Fair Lending option SPCP written plan versus actual originations can support after a board asking if the bank should settle a matched-pair study, then the two facts that force it, then the Monday action for second-review underwriter in a lender expanding into majority-minority census tracts.