Adverse-action notice operations lead must resolve whether a special-purpose

Situation

An underwriter chat that used coded language put manufactured-housing dealer overlay notes 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 a special-purpose program is from manufactured-housing dealer overlay notes, and the live options are A special-purpose program is well designed, A pretext.

Decision

Adverse-action notice operations lead in a credit union rolling out a special-purpose credit program must choose A special-purpose program is well designed / A pretext using manufactured-housing dealer overlay notes after an underwriter chat that used coded language.

Hypotheses to test

• An underwriter chat that used coded language is noise around an already-controlled Pricing and Credit Limits process in a credit union rolling out a special-purpose credit program, given manufactured-housing dealer overlay notes.
• An underwriter chat that used coded language is the event in manufactured-housing dealer overlay notes that forces A special-purpose program is well designed for adverse-action notice operations lead under Fair Lending.
• Manufactured-housing dealer overlay notes shows a one-file miss after an underwriter chat that used coded language, not a Pricing and Credit Limits program failure.
• Manufactured-housing dealer overlay notes cannot decide a special-purpose program is yet after an underwriter chat that used coded language; hold is the only Fair Lending close a credit union rolling out a special-purpose credit program can defend.

Analysis required

• Check HMDA coding and underwriting policy against a special-purpose program is.
• Compare manufactured-housing dealer overlay notes to similarly situated files, second-review notes, and reason codes after an underwriter chat that used coded language.
• Flag any disparate-impact table adverse-action notice operations lead cannot explain from manufactured-housing dealer overlay notes.
• For this Fair Lending Pricing and Credit Limits file, read manufactured-housing dealer overlay notes against an underwriter chat that used coded language and write the one fact that would move a special-purpose program is for adverse-action notice operations lead.

Recommendation