Assess whether to pause a product pending a lookback (b50547)

SITUATION Model-risk partner for credit scoring is responsible for to pause a product in a lender expanding into majority-minority census tracts, using underwriting exception log by branch as the only working extract. A SPCP that originated almost no loans to the intended class is what reset the timeline 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 underwriting exception log by branch after a SPCP that originated almost no loans to the intended class.

HYPOTHESES TO TEST 1. Underwriting exception log by branch reads as Remove access or reverse the item once a SPCP that originated almost no loans to the intended class is lined up to the same Fair Lending population. 2. Underwriting exception log by branch is closer to Temporary compensating control after a SPCP that originated almost no loans to the intended class; Remove access or reverse the item would over-claim this Examination and Notices extract. 3. Approve a documented exception is still live in underwriting exception log by branch for model-risk partner for credit scoring in a lender expanding into majority-minority census tracts. 4. Underwriting exception log by branch is missing the fact model-risk partner for credit scoring needs after a SPCP that originated almost no loans to the intended class; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern a lender expanding into majority-minority census tracts must defend. 2. Match the adverse-action language to the facts in underwriting exception log by branch. 3. Check HMDA coding and underwriting policy against to pause a product. 4. For this Fair Lending Examination and Notices file, read underwriting exception log by branch against a SPCP that originated almost no loans to the intended class 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 (underwriting exception log by branch after a SPCP that originated almost no loans to the intended class). The follow-on Examination and Notices action is what model-risk partner for credit scoring 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 underwriting exception log by branch, then the action for model-risk partner for credit scoring - Hypothesis scorecard against underwriting exception log by branch: supported / rejected / untestable - Regulatory or exam hook Examination and Notices would cite - Examination and Notices finding in underwriting exception log by branch that a second reviewer can re-perform