Assess whether to pause a product pending a lookback (10c9db)

SITUATION In a credit union rolling out a special-purpose credit program, underwriting exception log by branch is the evidence after a marketing mailer that skipped majority-minority tracts. 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 underwriting exception log by branch.

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 underwriting exception log by branch after a marketing mailer that skipped majority-minority tracts.

HYPOTHESES TO TEST 1. Second-review underwriter can defend Remove access or reverse the item from underwriting exception log by branch after a marketing mailer that skipped majority-minority tracts in a Fair Lending challenge. 2. Second-review underwriter cannot defend Remove access or reverse the item from underwriting exception log by branch; Temporary compensating control is what the extract actually supports after a marketing mailer that skipped majority-minority tracts. 3. A marketing mailer that skipped majority-minority tracts never reached the population in underwriting exception log by branch — reopen intake, do not close to pause a product. 4. Two facts in underwriting exception log by branch after a marketing mailer that skipped majority-minority tracts conflict for second-review underwriter; hold this Examination and Notices file.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in underwriting exception log by branch. 2. Check HMDA coding and underwriting policy against to pause a product. 3. Compare underwriting exception log by branch to similarly situated files, second-review notes, and reason codes after a marketing mailer that skipped majority-minority tracts. 4. For this Fair Lending Examination and Notices file, read underwriting exception log by branch against a marketing mailer that skipped majority-minority tracts 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 (underwriting exception log by branch after a marketing mailer that skipped majority-minority tracts). If underwriting exception log by branch 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.