Assess whether to pause a product pending a lookback (94d310)

SITUATION In a credit union rolling out a special-purpose credit program, a HMDA resubmission that still fails quality edits put SPCP written plan versus actual originations in play. Second-review underwriter should decide whether to pause a product pending a lookback without filling gaps SPCP written plan versus actual originations does not contain.

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 SPCP written plan versus actual originations after a HMDA resubmission that still fails quality edits.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; SPCP written plan versus actual originations already has the discriminator after a HMDA resubmission that still fails quality edits. 2. Keep Temporary compensating control in force until SPCP written plan versus actual originations is completed after a HMDA resubmission that still fails quality edits for second-review underwriter. 3. Treat SPCP written plan versus actual originations as Approve a documented exception because both readings appear after a HMDA resubmission that still fails quality edits. 4. Refuse a Fair Lending close: second-review underwriter does not have the decision to pause a product turns on in SPCP written plan versus actual originations.

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 SPCP written plan versus actual originations. 3. Check HMDA coding and underwriting policy against to pause a product. 4. For this Fair Lending Examination and Notices file, read SPCP written plan versus actual originations against a HMDA resubmission that still fails quality edits 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 (SPCP written plan versus actual originations after a HMDA resubmission that still fails quality edits). The follow-on Examination and Notices action is what second-review underwriter 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 second-review underwriter - Hypothesis scorecard against SPCP written plan versus actual originations: supported / rejected / untestable - What changes to pause a product if a HMDA resubmission that still fails quality edits is later withdrawn - Named option among Remove access or reverse the item, Temporary compensating control, Approve a documented exception and the fact that kills the others