Assess whether to pause a product pending a lookback after a DOJ or CFPB

SITUATION The working file is CRA assessment-area versus lending footprint after a DOJ or CFPB monitor request for pricing files. Model-risk partner for credit scoring in a small-business desk using a new vendor score has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending Pricing and Credit Limits file.

DECISION Model-risk partner for credit scoring 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 CRA assessment-area versus lending footprint after a DOJ or CFPB monitor request for pricing files.

HYPOTHESES TO TEST 1. CRA assessment-area versus lending footprint reads as Remove access or reverse the item once a DOJ or CFPB monitor request for pricing files is lined up to the same Fair Lending population. 2. CRA assessment-area versus lending footprint is closer to Temporary compensating control after a DOJ or CFPB monitor request for pricing files; Remove access or reverse the item would over-claim this Pricing and Credit Limits extract. 3. Approve a documented exception is still live in CRA assessment-area versus lending footprint for model-risk partner for credit scoring in a small-business desk using a new vendor score. 4. CRA assessment-area versus lending footprint is missing the fact model-risk partner for credit scoring needs after a DOJ or CFPB monitor request for pricing files; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in CRA assessment-area versus lending footprint. 2. Check HMDA coding and underwriting policy against to pause a product. 3. Compare CRA assessment-area versus lending footprint to similarly situated files, second-review notes, and reason codes after a DOJ or CFPB monitor request for pricing files. 4. For this Fair Lending Pricing and Credit Limits file, read CRA assessment-area versus lending footprint against a DOJ or CFPB monitor request for pricing files 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 / Pricing and Credit Limits packet (CRA assessment-area versus lending footprint after a DOJ or CFPB monitor request for pricing files). If CRA assessment-area versus lending footprint cannot force a Fair Lending label under Pricing and Credit Limits, stop. Do not invent missing evidence a small-business desk using a new vendor score does not have.

COMMAND RETURNS - Bottom-line Fair Lending option on to pause a product, then the evidence in CRA assessment-area versus lending footprint, then the action for model-risk partner for credit scoring - Hypothesis scorecard against CRA assessment-area versus lending footprint: supported / rejected / untestable - Regulatory or exam hook Pricing and Credit Limits would cite - Pricing and Credit Limits finding in CRA assessment-area versus lending footprint that a second reviewer can re-perform