Assess whether pricing disparities are justified by legitimate factors

SITUATION In a credit union rolling out a special-purpose credit program, SPCP written plan versus actual originations is the evidence after a branch that stopped taking applications in one ZIP. 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 SPCP written plan versus actual originations.

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 SPCP written plan versus actual originations after a branch that stopped taking applications in one ZIP.

HYPOTHESES TO TEST 1. A branch that stopped taking applications in one ZIP is noise around an already-controlled Pricing and Credit Limits process in a credit union rolling out a special-purpose credit program, given SPCP written plan versus actual originations. 2. A branch that stopped taking applications in one ZIP is the event in SPCP written plan versus actual originations that forces Remove access or reverse the item for adverse-action notice operations lead under Fair Lending. 3. SPCP written plan versus actual originations shows a one-file miss after a branch that stopped taking applications in one ZIP, not a Pricing and Credit Limits program failure. 4. SPCP written plan versus actual originations cannot decide pricing disparities are justified yet after a branch that stopped taking applications in one ZIP; hold is the only Fair Lending close a credit union rolling out a special-purpose credit program can defend.

ANALYSIS REQUIRED 1. Compare SPCP written plan versus actual originations to similarly situated files, second-review notes, and reason codes after a branch that stopped taking applications in one ZIP. 2. Flag any disparate-impact table adverse-action notice operations lead cannot explain from SPCP written plan versus actual originations. 3. Test a documented exception versus a pattern a credit union rolling out a special-purpose credit program must defend. 4. For this Fair Lending Pricing and Credit Limits file, read SPCP written plan versus actual originations against a branch that stopped taking applications in one ZIP and write the one fact that would move pricing disparities are justified for adverse-action notice operations lead.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Pricing and Credit Limits packet (SPCP written plan versus actual originations after a branch that stopped taking applications in one ZIP). Lead with the Fair Lending option SPCP written plan versus actual originations can support after a branch that stopped taking applications in one ZIP, then the two facts that force it, then the Monday action for adverse-action notice operations lead in a credit union rolling out a special-purpose credit program.