Whether to pause a product pending a lookback from small-business decline

SITUATION A credit union rolling out a special-purpose credit program cannot treat a vendor score change with no disparate-impact test as incidental context on small-business decline comparative file set. Adverse-action notice operations lead must close to pause a product from that extract under Fair Lending / Pricing and Credit Limits.

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 small-business decline comparative file set after a vendor score change with no disparate-impact test.

HYPOTHESES TO TEST 1. Small-business decline comparative file set after a vendor score change with no disparate-impact test supports Remove access or reverse the item for to pause a product if adverse-action notice operations lead can match the same Pricing and Credit Limits population in a credit union rolling out a special-purpose credit program. 2. Small-business decline comparative file set after a vendor score change with no disparate-impact test is closer to Temporary compensating control; calling Remove access or reverse the item would over-claim this Fair Lending extract. 3. Test a documented exception versus a pattern a credit union rolling out a special-purpose credit program must defend. is still a live third reading of small-business decline comparative file set that adverse-action notice operations lead has not closed. 4. Small-business decline comparative file set after a vendor score change with no disparate-impact test does not yet name the fact to pause a product turns on, so adverse-action notice operations lead should leave Fair Lending unresolved.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern a credit union rolling out a special-purpose credit program must defend. 2. Match the adverse-action language to the facts in small-business decline comparative file set. 3. Check HMDA coding and underwriting policy against to pause a product. 4. For this Fair Lending Pricing and Credit Limits file, read small-business decline comparative file set against a vendor score change with no disparate-impact test and write the one fact that would move to pause a product for adverse-action notice operations lead.

RECOMMENDATION From small-business decline comparative file set after a vendor score change with no disparate-impact test, choose Remove access or reverse the item when small-business decline comparative file set itself shows the discriminator for to pause a product. Adverse-action notice operations lead in a credit union rolling out a special-purpose credit program should implement that path on this Fair Lending Pricing and Credit Limits file and name the two facts in small-business decline comparative file set that force it. If small-business decline comparative file set after a vendor score change with no disparate-impact test cannot support Remove access or reverse the item versus Temporary compensating control, adverse-action notice operations lead must do not infer a control or scheme beyond the transaction and entitlement evidence.