Assess whether to pause a product pending a lookback (adf045)

SITUATION An exception rate twice as high for one group after credit controls put SPCP written plan versus actual originations in front of HMDA data-quality manager in a credit union rolling out a special-purpose credit program. This Fair Lending / CRA and Special-Purpose Programs close is to pause a product from SPCP written plan versus actual originations, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

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 SPCP written plan versus actual originations after an exception rate twice as high for one group after credit controls.

HYPOTHESES TO TEST 1. SPCP written plan versus actual originations reads as Remove access or reverse the item once an exception rate twice as high for one group after credit controls is lined up to the same Fair Lending population. 2. SPCP written plan versus actual originations is closer to Temporary compensating control after an exception rate twice as high for one group after credit controls; 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 SPCP written plan versus actual originations for HMDA data-quality manager in a credit union rolling out a special-purpose credit program. 4. SPCP written plan versus actual originations is missing the fact HMDA data-quality manager needs after an exception rate twice as high for one group after credit controls; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Flag any disparate-impact table HMDA data-quality manager cannot explain from SPCP written plan versus actual originations. 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 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 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 / CRA and Special-Purpose Programs packet (SPCP written plan versus actual originations after an exception rate twice as high for one group after credit controls). If SPCP written plan versus actual originations cannot force a Fair Lending label under CRA and Special-Purpose Programs, stop. If SPCP written plan versus actual originations after an exception rate twice as high for one group after credit controls cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending CRA and Special-Purpose Programs close, HMDA data-quality manager must do not infer a control or scheme beyond the transaction and entitlement evidence.