Whether comparative files show second-review bias from SPCP written plan

Situation

A credit union rolling out a special-purpose credit program cannot treat a SPCP that originated almost no loans to the intended class as color commentary on SPCP written plan versus actual originations. Adverse-action notice operations lead must close comparative files show second-review 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 SPCP written plan versus actual originations after a SPCP that originated almost no loans to the intended class.

Hypotheses to test

• A SPCP that originated almost no loans to the intended class 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.
• A SPCP that originated almost no loans to the intended class 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.
• SPCP written plan versus actual originations shows a one-file miss after a SPCP that originated almost no loans to the intended class, not a Pricing and Credit Limits program failure.
• SPCP written plan versus actual originations cannot decide comparative files show second-review yet after a SPCP that originated almost no loans to the intended class; hold is the only Fair Lending close a credit union rolling out a special-purpose credit program can defend.

Analysis required

• Compare SPCP written plan versus actual originations to similarly situated files, second-review notes, and reason codes after a SPCP that originated almost no loans to the intended class.
• Flag any disparate-impact table adverse-action notice operations lead cannot explain from SPCP written plan versus actual originations.
• Test a documented exception versus a pattern a credit union rolling out a special-purpose credit program must defend.
• For this Fair Lending Pricing and Credit Limits file, read SPCP written plan versus actual originations against a SPCP that originated almost no loans to the intended class and write the one fact that would move comparative files show second-review for adverse-action notice operations lead.