Assess whether to pause a product pending a lookback from geographic

SITUATION Adverse-action notice operations lead in a credit union rolling out a special-purpose credit program has one working extract — geographic application and origination heat map — after a branch that stopped taking applications in one ZIP. If geographic application and origination heat map cannot support to pause a product, the only defensible Fair Lending output is hold.

DECISION Adverse-action notice operations lead 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 geographic application and origination heat map after a branch that stopped taking applications in one ZIP.

HYPOTHESES TO TEST 1. A branch that stopped taking applications in one ZIP is noise around an already-controlled Pricing and Credit Limits process in a credit union rolling out a special-purpose credit program, given geographic application and origination heat map. 2. A branch that stopped taking applications in one ZIP is the event in geographic application and origination heat map that forces Remove access or reverse the item for adverse-action notice operations lead under Fair Lending. 3. Geographic application and origination heat map shows a one-file miss after a branch that stopped taking applications in one ZIP, not a Pricing and Credit Limits program failure. 4. Geographic application and origination heat map cannot decide to pause a product yet after a branch that stopped taking applications in one ZIP; hold is the only Fair Lending close a credit union rolling out a special-purpose credit program can defend.

ANALYSIS REQUIRED 1. Flag any disparate-impact table adverse-action notice operations lead cannot explain from geographic application and origination heat map. 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 geographic application and origination heat map. 4. For this Fair Lending Pricing and Credit Limits file, read geographic application and origination heat map against a branch that stopped taking applications in one ZIP and write the one fact that would move to pause a product for adverse-action notice operations lead.

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 (geographic application and origination heat map after a branch that stopped taking applications in one ZIP). The follow-on Pricing and Credit Limits action is what adverse-action notice operations lead does next: implement the option, assign an owner, and log the missing fact.