Assess whether to pause a product pending a lookback from SPCP written plan

SITUATION A mortgage company after a pricing-regression spike cannot treat a CRA PE that called the assessment area too narrow as incidental context on SPCP written plan versus actual originations. Fair-lending officer must close to pause a product from that extract under Fair Lending / Pricing and Credit Limits.

DECISION Fair-lending officer in a mortgage company after a pricing-regression spike 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 CRA PE that called the assessment area too narrow.

HYPOTHESES TO TEST 1. A CRA PE that called the assessment area too narrow is noise around an already-controlled Pricing and Credit Limits process in a mortgage company after a pricing-regression spike, given SPCP written plan versus actual originations. 2. A CRA PE that called the assessment area too narrow is the event in SPCP written plan versus actual originations that forces Remove access or reverse the item for fair-lending officer under Fair Lending. 3. SPCP written plan versus actual originations shows a one-file miss after a CRA PE that called the assessment area too narrow, not a Pricing and Credit Limits program failure. 4. SPCP written plan versus actual originations cannot decide to pause a product yet after a CRA PE that called the assessment area too narrow; hold is the only Fair Lending close a mortgage company after a pricing-regression spike can defend.

ANALYSIS REQUIRED 1. Flag any disparate-impact table fair-lending officer cannot explain from SPCP written plan versus actual originations. 2. Test a documented exception versus a pattern a mortgage company after a pricing-regression spike must defend. 3. Match the adverse-action language to the facts in SPCP written plan versus actual originations. 4. For this Fair Lending Pricing and Credit Limits file, read SPCP written plan versus actual originations against a CRA PE that called the assessment area too narrow and write the one fact that would move to pause a product for fair-lending officer.

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 (SPCP written plan versus actual originations after a CRA PE that called the assessment area too narrow). The follow-on Pricing and Credit Limits action is what fair-lending officer does next: implement the option, assign an owner, and log the missing fact.

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 fair-lending officer - Hypothesis scorecard against SPCP written plan versus actual originations: supported / rejected / untestable - Named option among Remove access or reverse the item, Temporary compensating control, Approve a documented exception and the fact that kills the others - Owner and next date for fair-lending officer in a mortgage company after a pricing-regression spike