Adverse-action notice operations lead must resolve whether notices match

Situation

In a credit union rolling out a special-purpose credit program, model-reason-code mapping that does not match notices is the evidence after a CRA PE that called the assessment area too narrow. Adverse-action notice operations lead has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending Pricing and Credit Limits close using model-reason-code mapping that does not match notices.

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 CRA PE that called the assessment area too narrow.

Hypotheses to test

• Adverse-action notice operations lead can defend Remove access or reverse the item from model-reason-code mapping that does not match notices after a CRA PE that called the assessment area too narrow in a Fair Lending challenge.
• Adverse-action notice operations lead cannot defend Remove access or reverse the item from model-reason-code mapping that does not match notices; Temporary compensating control is what the extract actually supports after a CRA PE that called the assessment area too narrow.
• A CRA PE that called the assessment area too narrow never reached the population in model-reason-code mapping that does not match notices — reopen intake, do not close notices match the actual.
• Two facts in model-reason-code mapping that does not match notices after a CRA PE that called the assessment area too narrow conflict for adverse-action notice operations lead; hold this Pricing and Credit Limits file.

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 CRA PE that called the assessment area too narrow and write the one fact that would move notices match the actual for adverse-action notice operations lead.