Assess whether to pause a product pending a lookback (a62e9e)

SITUATION Model-reason-code mapping that does not match notices arrived with a vendor score change with no disparate-impact test for fair-lending officer. That is a Fair Lending Examination and Notices decision on to pause a product in an institution preparing for a redlining exam.

DECISION Fair-lending officer in an institution preparing for a redlining exam 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 vendor score change with no disparate-impact test.

HYPOTHESES TO TEST 1. Fair-lending officer can defend Remove access or reverse the item from model-reason-code mapping that does not match notices after a vendor score change with no disparate-impact test in a Fair Lending challenge. 2. Fair-lending officer 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 vendor score change with no disparate-impact test. 3. A vendor score change with no disparate-impact test 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 vendor score change with no disparate-impact test conflict for fair-lending officer; hold this Examination and Notices file.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in model-reason-code mapping that does not match notices. 2. Check HMDA coding and underwriting policy against to pause a product. 3. Compare model-reason-code mapping that does not match notices to similarly situated files, second-review notes, and reason codes after a vendor score change with no disparate-impact test. 4. For this Fair Lending Examination and Notices file, read model-reason-code mapping that does not match notices against a vendor score change with no disparate-impact test and write the one fact that would move to pause a product for fair-lending officer.

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 vendor score change with no disparate-impact test). The follow-on Examination and Notices action is what fair-lending officer 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 model-reason-code mapping that does not match notices, then the action for fair-lending officer - Hypothesis scorecard against model-reason-code mapping that does not match notices: supported / rejected / untestable - Missing page in model-reason-code mapping that does not match notices after a vendor score change with no disparate-impact test, if any - Regulatory or exam hook Examination and Notices would cite