Assess whether to pause a product pending a lookback (531286)

SITUATION After a community complaint about appraisal gaps, underwriting exception log by branch is what HMDA data-quality manager can touch in a small-business desk using a new vendor score. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this Examination and Notices file.

DECISION HMDA data-quality manager in a small-business desk using a new vendor score must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using underwriting exception log by branch after a community complaint about appraisal gaps.

HYPOTHESES TO TEST 1. Underwriting exception log by branch reads as Remove access or reverse the item once a community complaint about appraisal gaps is lined up to the same Fair Lending population. 2. Underwriting exception log by branch is closer to Temporary compensating control after a community complaint about appraisal gaps; Remove access or reverse the item would over-claim this Examination and Notices extract. 3. Approve a documented exception is still live in underwriting exception log by branch for HMDA data-quality manager in a small-business desk using a new vendor score. 4. Underwriting exception log by branch is missing the fact HMDA data-quality manager needs after a community complaint about appraisal gaps; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern a small-business desk using a new vendor score must defend. 2. Match the adverse-action language to the facts in underwriting exception log by branch. 3. Check HMDA coding and underwriting policy against to pause a product. 4. For this Fair Lending Examination and Notices file, read underwriting exception log by branch against a community complaint about appraisal gaps 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 / Examination and Notices packet (underwriting exception log by branch after a community complaint about appraisal gaps). The follow-on Examination and Notices action is what HMDA data-quality manager does next: implement the option, assign an owner, and log the missing fact.

COMMAND RETURNS - Bottom-line Fair Lending option on to pause a product, then the evidence in underwriting exception log by branch, then the action for HMDA data-quality manager - Hypothesis scorecard against underwriting exception log by branch: supported / rejected / untestable - Examination and Notices finding in underwriting exception log by branch that a second reviewer can re-perform - Missing page in underwriting exception log by branch after a community complaint about appraisal gaps, if any