Assess whether to pause a product pending a lookback (21c778)

SITUATION Examination and Notices work in a credit union rolling out a special-purpose credit program now turns on to pause a product because a vendor score change with no disparate-impact test put manufactured-housing dealer overlay notes in play. Second-review underwriter should say what manufactured-housing dealer overlay notes proves.

DECISION Second-review underwriter 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 manufactured-housing dealer overlay notes after a vendor score change with no disparate-impact test.

HYPOTHESES TO TEST 1. Manufactured-housing dealer overlay notes reads as Remove access or reverse the item once a vendor score change with no disparate-impact test is lined up to the same Fair Lending population. 2. Manufactured-housing dealer overlay notes is closer to Temporary compensating control after a vendor score change with no disparate-impact test; Remove access or reverse the item would over-claim this Examination and Notices extract. 3. Approve a documented exception is still live in manufactured-housing dealer overlay notes for second-review underwriter in a credit union rolling out a special-purpose credit program. 4. Manufactured-housing dealer overlay notes is missing the fact second-review underwriter needs after a vendor score change with no disparate-impact test; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern a credit union rolling out a special-purpose credit program must defend. 2. Match the adverse-action language to the facts in manufactured-housing dealer overlay notes. 3. Check HMDA coding and underwriting policy against to pause a product. 4. For this Fair Lending Examination and Notices file, read manufactured-housing dealer overlay notes against a vendor score change with no disparate-impact test and write the one fact that would move to pause a product for second-review underwriter.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Examination and Notices packet (manufactured-housing dealer overlay notes after a vendor score change with no disparate-impact test). If manufactured-housing dealer overlay notes cannot force a Fair Lending label under Examination and Notices, stop. Do not invent missing evidence a credit union rolling out a special-purpose credit program does not have.

COMMAND RETURNS - Bottom-line Fair Lending option on to pause a product, then the evidence in manufactured-housing dealer overlay notes, then the action for second-review underwriter - Hypothesis scorecard against manufactured-housing dealer overlay notes: supported / rejected / untestable - Examination and Notices finding in manufactured-housing dealer overlay notes that a second reviewer can re-perform - Missing page in manufactured-housing dealer overlay notes after a vendor score change with no disparate-impact test, if any