Consumer Loan Origination (Unsecured, HELOC, Auto Direct) — impact tolerance ≤ 3 business days — ITOL

Impact tolerance: ≤ 3 business days — application pipeline stall causing ECOA 30-day adverse-action clock exposure, or funding delays beyond disclosed close date (illustrative default — trace the derivation, then replace with your own harm analysis)

Definition: Origination pipeline for consumer credit — application intake, underwriting decisioning, disclosures, and closing/funding for direct consumer loans and lines of credit.

Why it is designated: Origination can wait longer than servicing. But ECOA (the Equal Credit Opportunity Act) sets a 30-day statutory adverse-action clock, and for the HELOC leg, Reg Z's open-end early-disclosure rule (12 CFR §1026.40(b)) sets a 3-business-day timing requirement. (TRID's Closing Disclosure rule, 12 CFR §1026.19, doesn't apply here — it covers only closed-end credit secured by real property, not HELOC, unsecured, or auto loans.) Extended pipeline outages create fair-lending disparate-impact risk if some applicant segments sit queued longer than others.