Assess whether to pause a product pending a lookback (1a2e86)

SITUATION In a credit union rolling out a special-purpose credit program, model-reason-code mapping that does not match notices is the evidence after a notice that cites 'other' as the principal reason 40% of the time. Second-review underwriter has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending Examination and Notices close using model-reason-code mapping that does not match notices.

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 model-reason-code mapping that does not match notices after a notice that cites 'other' as the principal reason 40% of the time.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; model-reason-code mapping that does not match notices already has the discriminator after a notice that cites 'other' as the principal reason 40% of the time. 2. Keep Temporary compensating control in force until model-reason-code mapping that does not match notices is completed after a notice that cites 'other' as the principal reason 40% of the time for second-review underwriter. 3. Treat model-reason-code mapping that does not match notices as Approve a documented exception because both readings appear after a notice that cites 'other' as the principal reason 40% of the time. 4. Refuse a Fair Lending close: second-review underwriter does not have the decision to pause a product turns on in model-reason-code mapping that does not match notices.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in model-reason-code mapping that does not match notices. 2. Check HMDA coding and underwriting policy against to pause a product. 3. Compare model-reason-code mapping that does not match notices to similarly situated files, second-review notes, and reason codes after a notice that cites 'other' as the principal reason 40% of the time. 4. For this Fair Lending Examination and Notices file, read model-reason-code mapping that does not match notices against a notice that cites 'other' as the principal reason 40% of the time 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 (model-reason-code mapping that does not match notices after a notice that cites 'other' as the principal reason 40% of the time). If model-reason-code mapping that does not match notices 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.