Adverse-action notice operations lead must resolve whether comparative files

Situation

A credit union rolling out a special-purpose credit program cannot treat a board asking if the bank should settle a matched-pair study as color commentary on model-reason-code mapping that does not match notices. Adverse-action notice operations lead must close comparative files show second-review from that extract under Fair Lending / Pricing and Credit Limits.

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 model-reason-code mapping that does not match notices after a board asking if the bank should settle a matched-pair study.

Hypotheses to test

• A board asking if the bank should settle a matched-pair study is noise around an already-controlled Pricing and Credit Limits process in a credit union rolling out a special-purpose credit program, given model-reason-code mapping that does not match notices.
• A board asking if the bank should settle a matched-pair study is the event in model-reason-code mapping that does not match notices that forces Remove access or reverse the item for adverse-action notice operations lead under Fair Lending.
• Model-reason-code mapping that does not match notices shows a one-file miss after a board asking if the bank should settle a matched-pair study, not a Pricing and Credit Limits program failure.
• Model-reason-code mapping that does not match notices cannot decide comparative files show second-review yet after a board asking if the bank should settle a matched-pair study; hold is the only Fair Lending close a credit union rolling out a special-purpose credit program can defend.

Analysis required

• Flag any disparate-impact table adverse-action notice operations lead cannot explain from model-reason-code mapping that does not match notices.
• Test a documented exception versus a pattern a credit union rolling out a special-purpose credit program must defend.
• Match the adverse-action language to the facts in model-reason-code mapping that does not match notices.
• For this Fair Lending Pricing and Credit Limits file, read model-reason-code mapping that does not match notices against a board asking if the bank should settle a matched-pair study and write the one fact that would move comparative files show second-review for adverse-action notice operations lead.