Assess whether notices match the actual decisioning reasons (91e6a5)

SITUATION Second-review underwriter in a credit union rolling out a special-purpose credit program has one working extract — mortgage pricing residual by prohibited-basis group — after a vendor score change with no disparate-impact test. If mortgage pricing residual by prohibited-basis group cannot support notices match the actual, the only defensible Fair Lending output is hold.

DECISION Second-review underwriter 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 mortgage pricing residual by prohibited-basis group after a vendor score change with no disparate-impact test.

HYPOTHESES TO TEST 1. Second-review underwriter can defend Remove access or reverse the item from mortgage pricing residual by prohibited-basis group after a vendor score change with no disparate-impact test in a Fair Lending challenge. 2. Second-review underwriter cannot defend Remove access or reverse the item from mortgage pricing residual by prohibited-basis group; Temporary compensating control is what the extract actually supports after a vendor score change with no disparate-impact test. 3. A vendor score change with no disparate-impact test never reached the population in mortgage pricing residual by prohibited-basis group — reopen intake, do not close notices match the actual. 4. Two facts in mortgage pricing residual by prohibited-basis group after a vendor score change with no disparate-impact test conflict for second-review underwriter; hold this Examination and Notices file.

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 mortgage pricing residual by prohibited-basis group. 3. Check HMDA coding and underwriting policy against notices match the actual. 4. For this Fair Lending Examination and Notices file, read mortgage pricing residual by prohibited-basis group against a vendor score change with no disparate-impact test and write the one fact that would move notices match the actual for second-review underwriter.

RECOMMENDATION Treat this reading of mortgage pricing residual by prohibited-basis group as the gate for notices match the actual: Test a documented exception versus a pattern a credit union rolling out a special-purpose credit program must . If mortgage pricing residual by prohibited-basis group after a vendor score change with no disparate-impact test confirms that reading, second-review underwriter takes Remove access or reverse the item in a credit union rolling out a special-purpose credit program. If mortgage pricing residual by prohibited-basis group contradicts it, take Temporary compensating control.