Assess whether to pause a product pending a lookback (61a53c)

SITUATION A small-business desk using a new vendor score cannot treat a community complaint about appraisal gaps as incidental context on mortgage pricing residual by prohibited-basis group. Second-review underwriter must close to pause a product from that extract under Fair Lending / Redlining and HMDA Data.

DECISION Second-review underwriter 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 mortgage pricing residual by prohibited-basis group after a community complaint about appraisal gaps.

HYPOTHESES TO TEST 1. A community complaint about appraisal gaps is noise around an already-controlled Redlining and HMDA Data process in a small-business desk using a new vendor score, given mortgage pricing residual by prohibited-basis group. 2. A community complaint about appraisal gaps is the event in mortgage pricing residual by prohibited-basis group that forces Remove access or reverse the item for second-review underwriter under Fair Lending. 3. Mortgage pricing residual by prohibited-basis group shows a one-file miss after a community complaint about appraisal gaps, not a Redlining and HMDA Data program failure. 4. Mortgage pricing residual by prohibited-basis group cannot decide to pause a product yet after a community complaint about appraisal gaps; hold is the only Fair Lending close a small-business desk using a new vendor score can defend.

ANALYSIS REQUIRED 1. Flag any disparate-impact table second-review underwriter cannot explain from mortgage pricing residual by prohibited-basis group. 2. Test a documented exception versus a pattern a small-business desk using a new vendor score must defend. 3. Match the adverse-action language to the facts in mortgage pricing residual by prohibited-basis group. 4. For this Fair Lending Redlining and HMDA Data file, read mortgage pricing residual by prohibited-basis group against a community complaint about appraisal gaps 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 / Redlining and HMDA Data packet (mortgage pricing residual by prohibited-basis group after a community complaint about appraisal gaps). Lead with the Fair Lending option mortgage pricing residual by prohibited-basis group can support after a community complaint about appraisal gaps, then the two facts that force it, then the Monday action for second-review underwriter in a small-business desk using a new vendor score.