Assess whether to pause a product pending a lookback (b397f4)

SITUATION The working file is SPCP written plan versus actual originations after a community complaint about appraisal gaps. Model-risk partner for credit scoring in a lender expanding into majority-minority census tracts has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending Examination and Notices file.

DECISION Model-risk partner for credit scoring in a lender expanding into majority-minority census tracts must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using SPCP written plan versus actual originations after a community complaint about appraisal gaps.

HYPOTHESES TO TEST 1. The population in SPCP written plan versus actual originations is the one a community complaint about appraisal gaps named, so Remove access or reverse the item follows for this Examination and Notices file. 2. The population in SPCP written plan versus actual originations is adjacent only to a community complaint about appraisal gaps; Temporary compensating control is the honest Fair Lending call. 3. A lender expanding into majority-minority census tracts already contained a community complaint about appraisal gaps before SPCP written plan versus actual originations arrived; no new Examination and Notices path. 4. Provenance on SPCP written plan versus actual originations after a community complaint about appraisal gaps is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in SPCP written plan versus actual originations. 2. Check HMDA coding and underwriting policy against to pause a product. 3. Compare SPCP written plan versus actual originations to similarly situated files, second-review notes, and reason codes after a community complaint about appraisal gaps. 4. For this Fair Lending Examination and Notices file, read SPCP written plan versus actual originations against a community complaint about appraisal gaps 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 / Examination and Notices packet (SPCP written plan versus actual originations after a community complaint about appraisal gaps). If SPCP written plan versus actual originations cannot force a Fair Lending label under Examination and Notices, stop. Do not invent missing evidence a lender expanding into majority-minority census tracts does not have.

COMMAND RETURNS - Bottom-line Fair Lending option on to pause a product, then the evidence in SPCP written plan versus actual originations, then the action for model-risk partner for credit scoring - Hypothesis scorecard against SPCP written plan versus actual originations: supported / rejected / untestable - Owner and next date for model-risk partner for credit scoring in a lender expanding into majority-minority census tracts - What changes to pause a product if a community complaint about appraisal gaps is later withdrawn