Assess whether the exam response should concede a finding from SPCP written

SITUATION After an underwriter chat that used coded language, SPCP written plan versus actual originations is what adverse-action notice operations lead can touch in a credit union rolling out a special-purpose credit program. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this 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 SPCP written plan versus actual originations after an underwriter chat that used coded language.

HYPOTHESES TO TEST 1. 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 SPCP written plan versus actual originations. 2. An underwriter chat that used coded language 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. 3. SPCP written plan versus actual originations shows a one-file miss after an underwriter chat that used coded language, not a Pricing and Credit Limits program failure. 4. SPCP written plan versus actual originations cannot decide the exam response should 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 1. Check HMDA coding and underwriting policy against the exam response should. 2. Compare SPCP written plan versus actual originations to similarly situated files, second-review notes, and reason codes after an underwriter chat that used coded language. 3. Flag any disparate-impact table adverse-action notice operations lead cannot explain from SPCP written plan versus actual originations. 4. For this Fair Lending Pricing and Credit Limits file, read SPCP written plan versus actual originations against an underwriter chat that used coded language and write the one fact that would move the exam response should 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 (SPCP written plan versus actual originations after an underwriter chat that used coded language). If SPCP written plan versus actual originations cannot force a Fair Lending label under Pricing and Credit Limits, stop. If SPCP written plan versus actual originations after an underwriter chat that used coded language cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending Pricing and Credit Limits close, adverse-action notice operations lead must do not infer a control or scheme beyond the transaction and entitlement evidence.