Assess whether to pause a product pending a lookback (570a39)

SITUATION A marketing mailer that skipped majority-minority tracts put model-reason-code mapping that does not match notices in front of adverse-action notice operations lead in a credit-card issuer changing line-assignment logic. This Fair Lending / Examination and Notices close is to pause a product from model-reason-code mapping that does not match notices, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

DECISION Adverse-action notice operations lead in a credit-card issuer changing line-assignment logic must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using model-reason-code mapping that does not match notices after a marketing mailer that skipped majority-minority tracts.

HYPOTHESES TO TEST 1. Adverse-action notice operations lead can defend Remove access or reverse the item from model-reason-code mapping that does not match notices after a marketing mailer that skipped majority-minority tracts in a Fair Lending challenge. 2. Adverse-action notice operations lead cannot defend Remove access or reverse the item from model-reason-code mapping that does not match notices; Temporary compensating control is what the extract actually supports after a marketing mailer that skipped majority-minority tracts. 3. A marketing mailer that skipped majority-minority tracts never reached the population in model-reason-code mapping that does not match notices — reopen intake, do not close to pause a product. 4. Two facts in model-reason-code mapping that does not match notices after a marketing mailer that skipped majority-minority tracts conflict for adverse-action notice operations lead; hold this Examination and Notices file.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against to pause a product. 2. Compare model-reason-code mapping that does not match notices to similarly situated files, second-review notes, and reason codes after a marketing mailer that skipped majority-minority tracts. 3. Flag any disparate-impact table adverse-action notice operations lead cannot explain from model-reason-code mapping that does not match notices. 4. For this Fair Lending Examination and Notices file, read model-reason-code mapping that does not match notices against a marketing mailer that skipped majority-minority tracts 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 / Examination and Notices packet (model-reason-code mapping that does not match notices after a marketing mailer that skipped majority-minority tracts). Lead with the Fair Lending option model-reason-code mapping that does not match notices can support after a marketing mailer that skipped majority-minority tracts, then the two facts that force it, then the Monday action for adverse-action notice operations lead in a credit-card issuer changing line-assignment logic.