Assess whether comparative files show second-review bias from adverse-action

SITUATION Adverse-action notice operations lead in a credit union rolling out a special-purpose credit program has one working extract — adverse-action notice principal-reason sample — after a branch that stopped taking applications in one ZIP. If adverse-action notice principal-reason sample cannot support comparative files show second-review, the only defensible Fair Lending output is hold.

DECISION Adverse-action notice operations lead 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 adverse-action notice principal-reason sample after a branch that stopped taking applications in one ZIP.

HYPOTHESES TO TEST 1. A branch that stopped taking applications in one ZIP is noise around an already-controlled Pricing and Credit Limits process in a credit union rolling out a special-purpose credit program, given adverse-action notice principal-reason sample. 2. A branch that stopped taking applications in one ZIP is the event in adverse-action notice principal-reason sample that forces Remove access or reverse the item for adverse-action notice operations lead under Fair Lending. 3. Adverse-action notice principal-reason sample shows a one-file miss after a branch that stopped taking applications in one ZIP, not a Pricing and Credit Limits program failure. 4. Adverse-action notice principal-reason sample cannot decide comparative files show second-review yet after a branch that stopped taking applications in one ZIP; hold is the only Fair Lending close a credit union rolling out a special-purpose credit program can defend.

ANALYSIS REQUIRED 1. Compare adverse-action notice principal-reason sample to similarly situated files, second-review notes, and reason codes after a branch that stopped taking applications in one ZIP. 2. Flag any disparate-impact table adverse-action notice operations lead cannot explain from adverse-action notice principal-reason sample. 3. Test a documented exception versus a pattern a credit union rolling out a special-purpose credit program must defend. 4. For this Fair Lending Pricing and Credit Limits file, read adverse-action notice principal-reason sample against a branch that stopped taking applications in one ZIP and write the one fact that would move comparative files show second-review for adverse-action notice operations lead.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Pricing and Credit Limits packet (adverse-action notice principal-reason sample after a branch that stopped taking applications in one ZIP). If adverse-action notice principal-reason sample cannot force a Fair Lending label under Pricing and Credit Limits, stop. If adverse-action notice principal-reason sample after a branch that stopped taking applications in one ZIP cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending Pricing and Credit Limits close, adverse-action notice operations lead must do not infer a control or scheme beyond the transaction and entitlement evidence.