Assess whether comparative files show second-review bias (7d7049)

Situation

After an underwriter chat that used coded language, SPCP written plan versus actual originations is what second-review underwriter can touch in a credit union rolling out a special-purpose credit program. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this Examination and Notices file.

Decision

Second-review underwriter 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 SPCP written plan versus actual originations after an underwriter chat that used coded language.

Hypotheses to test

• An underwriter chat that used coded language is noise around an already-controlled Examination and Notices process in a credit union rolling out a special-purpose credit program, given SPCP written plan versus actual originations.
• An underwriter chat that used coded language is the event in SPCP written plan versus actual originations that forces Remove access or reverse the item for second-review underwriter under Fair Lending.
• SPCP written plan versus actual originations shows a one-file miss after an underwriter chat that used coded language, not a Examination and Notices program failure.
• SPCP written plan versus actual originations cannot decide comparative files show second-review yet after an underwriter chat that used coded language; hold is the only Fair Lending close a credit union rolling out a special-purpose credit program can defend.

Analysis required

• 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 SPCP written plan versus actual originations.
• Check HMDA coding and underwriting policy against comparative files show second-review.
• For this Fair Lending Examination and Notices file, read SPCP written plan versus actual originations against an underwriter chat that used coded language and write the one fact that would move comparative files show second-review for second-review underwriter.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Examination and Notices packet (SPCP written plan versus actual originations after an underwriter chat that used coded language). If SPCP written plan versus actual originations cannot force a Fair Lending label under Examination and Notices, stop. Do not invent pages a credit union rolling out a special-purpose credit program does not have.