Assess whether to pause a product pending a lookback (8e688c)

SITUATION A branch that stopped taking applications in one ZIP put underwriting exception log by branch in front of model-risk partner for credit scoring in a lender expanding into majority-minority census tracts. This Fair Lending / Examination and Notices close is to pause a product from underwriting exception log by branch, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

DECISION Model-risk partner for credit scoring in a lender expanding into majority-minority census tracts must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using underwriting exception log by branch after a branch that stopped taking applications in one ZIP.

HYPOTHESES TO TEST 1. Model-risk partner for credit scoring can defend Remove access or reverse the item from underwriting exception log by branch after a branch that stopped taking applications in one ZIP in a Fair Lending challenge. 2. Model-risk partner for credit scoring cannot defend Remove access or reverse the item from underwriting exception log by branch; Temporary compensating control is what the extract actually supports after a branch that stopped taking applications in one ZIP. 3. A branch that stopped taking applications in one ZIP never reached the population in underwriting exception log by branch — reopen intake, do not close to pause a product. 4. Two facts in underwriting exception log by branch after a branch that stopped taking applications in one ZIP conflict for model-risk partner for credit scoring; hold this Examination and Notices file.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern a lender expanding into majority-minority census tracts must defend. 2. Match the adverse-action language to the facts in underwriting exception log by branch. 3. Check HMDA coding and underwriting policy against to pause a product. 4. For this Fair Lending Examination and Notices file, read underwriting exception log by branch against a branch that stopped taking applications in one ZIP 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 / Examination and Notices packet (underwriting exception log by branch after a branch that stopped taking applications in one ZIP). If underwriting exception log by branch cannot force a Fair Lending label under Examination and Notices, stop. Do not invent missing evidence a lender expanding into majority-minority census tracts does not have.