Assess whether notices match the actual decisioning reasons (79bad1)

SITUATION The working file is adverse-action notice principal-reason sample after a notice that cites 'other' as the principal reason 40% of the time. Second-review underwriter in a small-business desk using a new vendor score has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending Redlining and HMDA Data file.

DECISION Second-review underwriter in a small-business desk using a new vendor score must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using adverse-action notice principal-reason sample after a notice that cites 'other' as the principal reason 40% of the time.

HYPOTHESES TO TEST 1. Second-review underwriter can defend Remove access or reverse the item from adverse-action notice principal-reason sample after a notice that cites 'other' as the principal reason 40% of the time in a Fair Lending challenge. 2. Second-review underwriter cannot defend Remove access or reverse the item from adverse-action notice principal-reason sample; 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 adverse-action notice principal-reason sample — reopen intake, do not close notices match the actual. 4. Two facts in adverse-action notice principal-reason sample after a notice that cites 'other' as the principal reason 40% of the time conflict for second-review underwriter; hold this Redlining and HMDA Data file.

ANALYSIS REQUIRED 1. Flag any disparate-impact table second-review underwriter cannot explain from adverse-action notice principal-reason sample. 2. Test a documented exception versus a pattern a small-business desk using a new vendor score must defend. 3. Match the adverse-action language to the facts in adverse-action notice principal-reason sample. 4. For this Fair Lending Redlining and HMDA Data file, read adverse-action notice principal-reason sample against a notice that cites 'other' as the principal reason 40% of the time and write the one fact that would move notices match the actual for second-review underwriter.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Redlining and HMDA Data packet (adverse-action notice principal-reason sample after a notice that cites 'other' as the principal reason 40% of the time). Lead with the Fair Lending option adverse-action notice principal-reason sample 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 second-review underwriter in a small-business desk using a new vendor score.