Whether notices match the actual decisioning reasons from adverse-action

Situation

After an exception rate twice as high for one group after credit controls, adverse-action notice principal-reason sample is what exam-response coordinator can touch in an institution preparing for a redlining exam. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this Pricing and Credit Limits file.

Decision

Exam-response coordinator in an institution preparing for a redlining exam must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using adverse-action notice principal-reason sample after an exception rate twice as high for one group after credit controls.

Hypotheses to test

• The population in adverse-action notice principal-reason sample is the one an exception rate twice as high for one group after credit controls named, so Remove access or reverse the item follows for this Pricing and Credit Limits file.
• The population in adverse-action notice principal-reason sample is adjacent only to an exception rate twice as high for one group after credit controls; Temporary compensating control is the honest Fair Lending call.
• An institution preparing for a redlining exam already contained an exception rate twice as high for one group after credit controls before adverse-action notice principal-reason sample arrived; no new Pricing and Credit Limits path.
• Provenance on adverse-action notice principal-reason sample after an exception rate twice as high for one group after credit controls is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Check HMDA coding and underwriting policy against notices match the actual.
• Compare adverse-action notice principal-reason sample to similarly situated files, second-review notes, and reason codes after an exception rate twice as high for one group after credit controls.
• Flag any disparate-impact table exam-response coordinator cannot explain from adverse-action notice principal-reason sample.
• For this Fair Lending Pricing and Credit Limits file, read adverse-action notice principal-reason sample against an exception rate twice as high for one group after credit controls and write the one fact that would move notices match the actual for exam-response coordinator.