Assess whether to pause a product pending a lookback (648a4d)

SITUATION Redlining and HMDA Data work in a credit union rolling out a special-purpose credit program now turns on to pause a product because a notice that cites 'other' as the principal reason 40% of the time put geographic application and origination heat map in play. Model-risk partner for credit scoring should say what geographic application and origination heat map proves.

DECISION Model-risk partner for credit scoring 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 notice that cites 'other' as the principal reason 40% of the time.

HYPOTHESES TO TEST 1. Model-risk partner for credit scoring can defend Remove access or reverse the item from geographic application and origination heat map after a notice that cites 'other' as the principal reason 40% of the time in a Fair Lending challenge. 2. Model-risk partner for credit scoring cannot defend Remove access or reverse the item from geographic application and origination heat map; Temporary compensating control is what the extract actually supports after a notice that cites 'other' as the principal reason 40% of the time. 3. A notice that cites 'other' as the principal reason 40% of the time never reached the population in geographic application and origination heat map — reopen intake, do not close to pause a product. 4. Two facts in geographic application and origination heat map after a notice that cites 'other' as the principal reason 40% of the time conflict for model-risk partner for credit scoring; hold this Redlining and HMDA Data file.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern a credit union rolling out a special-purpose credit program must defend. 2. Match the adverse-action language to the facts in geographic application and origination heat map. 3. Check HMDA coding and underwriting policy against to pause a product. 4. For this Fair Lending Redlining and HMDA Data file, read geographic application and origination heat map against a notice that cites 'other' as the principal reason 40% of the time and write the one fact that would move to pause a product for model-risk partner for credit scoring.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Redlining and HMDA Data packet (geographic application and origination heat map after a notice that cites 'other' as the principal reason 40% of the time). Lead with the Fair Lending option geographic application and origination heat map can support after a notice that cites 'other' as the principal reason 40% of the time, then the two facts that force it, then the Monday action for model-risk partner for credit scoring in a credit union rolling out a special-purpose credit program.