Assess whether to pause a product pending a lookback (94360d)

SITUATION A credit union rolling out a special-purpose credit program cannot treat a marketing mailer that skipped majority-minority tracts as incidental context on mortgage pricing residual by prohibited-basis group. Second-review underwriter must close to pause a product from that extract under Fair Lending / Examination and Notices.

DECISION Second-review underwriter 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 mortgage pricing residual by prohibited-basis group after a marketing mailer that skipped majority-minority tracts.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; mortgage pricing residual by prohibited-basis group already has the discriminator after a marketing mailer that skipped majority-minority tracts. 2. Keep Temporary compensating control in force until mortgage pricing residual by prohibited-basis group is completed after a marketing mailer that skipped majority-minority tracts for second-review underwriter. 3. Treat mortgage pricing residual by prohibited-basis group as Approve a documented exception because both readings appear after a marketing mailer that skipped majority-minority tracts. 4. Refuse a Fair Lending close: second-review underwriter does not have the decision to pause a product turns on in mortgage pricing residual by prohibited-basis group.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against to pause a product. 2. Compare mortgage pricing residual by prohibited-basis group 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 second-review underwriter cannot explain from mortgage pricing residual by prohibited-basis group. 4. For this Fair Lending Examination and Notices file, read mortgage pricing residual by prohibited-basis group against a marketing mailer that skipped majority-minority tracts and write the one fact that would move to pause a product for second-review underwriter.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Examination and Notices packet (mortgage pricing residual by prohibited-basis group after a marketing mailer that skipped majority-minority tracts). Lead with the Fair Lending option mortgage pricing residual by prohibited-basis group can support after a marketing mailer that skipped majority-minority tracts, then the two facts that force it, then the Monday action for second-review underwriter in a credit union rolling out a special-purpose credit program.