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 TRID (the TILA-RESPA integrated disclosure rule) fixes disclosure timing. Extended pipeline outages create fair-lending disparate-impact risk if some applicant segments sit queued longer than others.