Assess whether comparative files show second-review bias after a notice that

SITUATION The working file is model-reason-code mapping that does not match notices after a notice that cites 'other' as the principal reason 40% of the time. Adverse-action notice operations lead in a credit union rolling out a special-purpose credit program has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending Pricing and Credit Limits file.

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 notice that cites 'other' as the principal reason 40% of the time.

HYPOTHESES TO TEST 1. 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 notice that cites 'other' as the principal reason 40% of the time in a Fair Lending challenge. 2. 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 notice that cites 'other' as the principal reason 40% of the time. 3. A notice that cites 'other' as the principal reason 40% of the time never reached the population in model-reason-code mapping that does not match notices — reopen intake, do not close comparative files show second-review. 4. Two facts in model-reason-code mapping that does not match notices after a notice that cites 'other' as the principal reason 40% of the time conflict for adverse-action notice operations lead; hold this Pricing and Credit Limits file.

ANALYSIS REQUIRED 1. Compare model-reason-code mapping that does not match notices to similarly situated files, second-review notes, and reason codes after a notice that cites 'other' as the principal reason 40% of the time. 2. Flag any disparate-impact table adverse-action notice operations lead cannot explain from model-reason-code mapping that does not match notices. 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 model-reason-code mapping that does not match notices against a notice that cites 'other' as the principal reason 40% of the time and write the one fact that would move comparative files show second-review 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 (model-reason-code mapping that does not match notices after a notice that cites 'other' as the principal reason 40% of the time). Lead with the Fair Lending option model-reason-code mapping that does not match notices can support after a notice that cites 'other' as the principal reason 40% of the time, 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.