Assess whether to pause a product pending a lookback (2f7d87)

SITUATION In a credit union rolling out a special-purpose credit program, a board asking if the bank should settle a matched-pair study put appraisal-gap outcomes in majority-minority tracts in play. Model-risk partner for credit scoring should decide whether to pause a product pending a lookback without filling gaps appraisal-gap outcomes in majority-minority tracts does not contain.

DECISION Model-risk partner for credit scoring 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 appraisal-gap outcomes in majority-minority tracts after a board asking if the bank should settle a matched-pair study.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; appraisal-gap outcomes in majority-minority tracts already has the discriminator after a board asking if the bank should settle a matched-pair study. 2. Keep Temporary compensating control in force until appraisal-gap outcomes in majority-minority tracts is completed after a board asking if the bank should settle a matched-pair study for model-risk partner for credit scoring. 3. Treat appraisal-gap outcomes in majority-minority tracts as Approve a documented exception because both readings appear after a board asking if the bank should settle a matched-pair study. 4. Refuse a Fair Lending close: model-risk partner for credit scoring does not have the decision to pause a product turns on in appraisal-gap outcomes in majority-minority tracts.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against to pause a product. 2. Compare appraisal-gap outcomes in majority-minority tracts to similarly situated files, second-review notes, and reason codes after a board asking if the bank should settle a matched-pair study. 3. Flag any disparate-impact table model-risk partner for credit scoring cannot explain from appraisal-gap outcomes in majority-minority tracts. 4. For this Fair Lending Redlining and HMDA Data file, read appraisal-gap outcomes in majority-minority tracts against a board asking if the bank should settle a matched-pair study 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 / Redlining and HMDA Data packet (appraisal-gap outcomes in majority-minority tracts after a board asking if the bank should settle a matched-pair study). If appraisal-gap outcomes in majority-minority tracts cannot force a Fair Lending label under Redlining and HMDA Data, stop. If appraisal-gap outcomes in majority-minority tracts after a board asking if the bank should settle a matched-pair study cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending Redlining and HMDA Data close, model-risk partner for credit scoring must do not infer a control or scheme beyond the transaction and entitlement evidence.