Assess whether to pause a product pending a lookback (4cd045)

SITUATION CRA and Special-Purpose Programs work in a small-business desk using a new vendor score now turns on to pause a product because a SPCP that originated almost no loans to the intended class put mortgage pricing residual by prohibited-basis group in play. Adverse-action notice operations lead should say what mortgage pricing residual by prohibited-basis group proves.

DECISION Adverse-action notice operations lead in a small-business desk using a new vendor score 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 SPCP that originated almost no loans to the intended class.

HYPOTHESES TO TEST 1. Adverse-action notice operations lead can defend Remove access or reverse the item from mortgage pricing residual by prohibited-basis group after a SPCP that originated almost no loans to the intended class in a Fair Lending challenge. 2. Adverse-action notice operations lead cannot defend Remove access or reverse the item from mortgage pricing residual by prohibited-basis group; Temporary compensating control is what the extract actually supports after a SPCP that originated almost no loans to the intended class. 3. A SPCP that originated almost no loans to the intended class never reached the population in mortgage pricing residual by prohibited-basis group — reopen intake, do not close to pause a product. 4. Two facts in mortgage pricing residual by prohibited-basis group after a SPCP that originated almost no loans to the intended class conflict for adverse-action notice operations lead; hold this CRA and Special-Purpose Programs file.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in mortgage pricing residual by prohibited-basis group. 2. Check HMDA coding and underwriting policy against to pause a product. 3. Compare mortgage pricing residual by prohibited-basis group to similarly situated files, second-review notes, and reason codes after a SPCP that originated almost no loans to the intended class. 4. For this Fair Lending CRA and Special-Purpose Programs file, read mortgage pricing residual by prohibited-basis group against a SPCP that originated almost no loans to the intended class 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 / CRA and Special-Purpose Programs packet (mortgage pricing residual by prohibited-basis group after a SPCP that originated almost no loans to the intended class). Lead with the Fair Lending option mortgage pricing residual by prohibited-basis group can support after a SPCP that originated almost no loans to the intended class, then the two facts that force it, then the Monday action for adverse-action notice operations lead in a small-business desk using a new vendor score.