Assess whether notices match the actual decisioning reasons (176a2b)

SITUATION CRA and Special-Purpose Programs work in a credit union rolling out a special-purpose credit program now turns on notices match the actual because a board asking if the bank should settle a matched-pair study put adverse-action notice principal-reason sample in play. CRA and Special-Purpose Programs work in a credit union rolling out a special-purpose credit program now turns on notices match the actual because a board asking if the bank should settle a matched-pair study put adverse-action notice principal-reason sample in play; HMDA data-quality manager should say what adverse-action notice principal-reason sample proves for Fair Lending.

DECISION HMDA data-quality manager 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 board asking if the bank should settle a matched-pair study.

HYPOTHESES TO TEST 1. HMDA data-quality manager can defend Remove access or reverse the item from adverse-action notice principal-reason sample after a board asking if the bank should settle a matched-pair study in a Fair Lending challenge. 2. HMDA data-quality manager cannot defend Remove access or reverse the item from adverse-action notice principal-reason sample; Temporary compensating control is what the extract actually supports after a board asking if the bank should settle a matched-pair study. 3. A board asking if the bank should settle a matched-pair study never reached the population in adverse-action notice principal-reason sample — reopen intake, do not close notices match the actual. 4. Two facts in adverse-action notice principal-reason sample after a board asking if the bank should settle a matched-pair study conflict for HMDA data-quality manager; hold this CRA and Special-Purpose Programs file.

ANALYSIS REQUIRED 1. Flag any disparate-impact table HMDA data-quality manager cannot explain from adverse-action notice principal-reason sample. 2. Test a documented exception versus a pattern a credit union rolling out a special-purpose credit program must defend. 3. Match the adverse-action language to the facts in adverse-action notice principal-reason sample. 4. For this Fair Lending CRA and Special-Purpose Programs file, read adverse-action notice principal-reason sample against a board asking if the bank should settle a matched-pair study and write the one fact that would move notices match the actual for HMDA data-quality manager.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / CRA and Special-Purpose Programs packet (adverse-action notice principal-reason sample after a board asking if the bank should settle a matched-pair study). If adverse-action notice principal-reason sample cannot force a Fair Lending label under CRA and Special-Purpose Programs, stop. If adverse-action notice principal-reason sample after a board asking if the bank should settle a matched-pair study cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending CRA and Special-Purpose Programs close, HMDA data-quality manager must do not infer a control or scheme beyond the transaction and entitlement evidence.