Adverse-action notice operations lead must resolve whether the exam response

Situation

A notice that cites 'other' as the principal reason 40% of the time put adverse-action notice principal-reason sample in front of adverse-action notice operations lead in a credit union rolling out a special-purpose credit program. This Fair Lending / Pricing and Credit Limits close is the exam response should from adverse-action notice principal-reason sample, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

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 notice that cites 'other' as the principal reason 40% of the time.

Hypotheses to test

• Adverse-action notice principal-reason sample reads as Remove access or reverse the item once a notice that cites 'other' as the principal reason 40% of the time is lined up to the same Fair Lending population.
• Adverse-action notice principal-reason sample is closer to Temporary compensating control after a notice that cites 'other' as the principal reason 40% of the time; Remove access or reverse the item would over-claim this Pricing and Credit Limits extract.
• Approve a documented exception is still live in adverse-action notice principal-reason sample for adverse-action notice operations lead in a credit union rolling out a special-purpose credit program.
• Adverse-action notice principal-reason sample is missing the fact adverse-action notice operations lead needs after a notice that cites 'other' as the principal reason 40% of the time; stop this Fair Lending close.

Analysis required

• Compare adverse-action notice principal-reason sample to similarly situated files, second-review notes, and reason codes after a notice that cites 'other' as the principal reason 40% of the time.
• Flag any disparate-impact table adverse-action notice operations lead cannot explain from adverse-action notice principal-reason sample.
• Test a documented exception versus a pattern a credit union rolling out a special-purpose credit program must defend.
• For this Fair Lending Pricing and Credit Limits file, read adverse-action notice principal-reason sample against a notice that cites 'other' as the principal reason 40% of the time and write the one fact that would move the exam response should for adverse-action notice operations lead.