Assess whether to pause a product pending a lookback (c1df3f)

SITUATION In a manufactured-housing lender with dealer-originated files, appraisal-gap outcomes in majority-minority tracts is the evidence after a vendor score change with no disparate-impact test. Fair-lending officer has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending Redlining and HMDA Data close using appraisal-gap outcomes in majority-minority tracts.

DECISION Fair-lending officer in a manufactured-housing lender with dealer-originated files 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 vendor score change with no disparate-impact test.

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 vendor score change with no disparate-impact test. 2. Keep Temporary compensating control in force until appraisal-gap outcomes in majority-minority tracts is completed after a vendor score change with no disparate-impact test for fair-lending officer. 3. Treat appraisal-gap outcomes in majority-minority tracts as Approve a documented exception because both readings appear after a vendor score change with no disparate-impact test. 4. Refuse a Fair Lending close: fair-lending officer does not have the decision to pause a product turns on in appraisal-gap outcomes in majority-minority tracts.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in appraisal-gap outcomes in majority-minority tracts. 2. Check HMDA coding and underwriting policy against to pause a product. 3. Compare appraisal-gap outcomes in majority-minority tracts 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 Redlining and HMDA Data file, read appraisal-gap outcomes in majority-minority tracts 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 / Redlining and HMDA Data packet (appraisal-gap outcomes in majority-minority tracts after a vendor score change with no disparate-impact test). The follow-on Redlining and HMDA Data 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 appraisal-gap outcomes in majority-minority tracts, then the action for fair-lending officer - Hypothesis scorecard against appraisal-gap outcomes in majority-minority tracts: supported / rejected / untestable - Redlining and HMDA Data finding in appraisal-gap outcomes in majority-minority tracts that a second reviewer can re-perform - Missing page in appraisal-gap outcomes in majority-minority tracts after a vendor score change with no disparate-impact test, if any