Whether a special-purpose program is well designed or a pretext from SPCP

Situation

Adverse-action notice operations lead owns a special-purpose program is inside a credit union rolling out a special-purpose credit program with SPCP written plan versus actual originations as the only packet. A notice that cites 'other' as the principal reason 40% of the time is what changed the clock 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 A special-purpose program is well designed / A pretext using SPCP written plan versus actual originations after a notice that cites 'other' as the principal reason 40% of the time.

Hypotheses to test

• The population in SPCP written plan versus actual originations is the one a notice that cites 'other' as the principal reason 40% of the time named, so A special-purpose program is well designed follows for this Pricing and Credit Limits file.
• The population in SPCP written plan versus actual originations is adjacent only to a notice that cites 'other' as the principal reason 40% of the time; A pretext is the honest Fair Lending call.
• A credit union rolling out a special-purpose credit program already contained a notice that cites 'other' as the principal reason 40% of the time before SPCP written plan versus actual originations arrived; no new Pricing and Credit Limits path.
• Provenance on SPCP written plan versus actual originations after a notice that cites 'other' as the principal reason 40% of the time is broken; do not pick A special-purpose program is well designed or A pretext yet.

Analysis required

• Compare SPCP written plan versus actual originations to similarly situated files, second-review notes, and reason codes after a notice that cites 'other' as the principal reason 40% of the time.
• 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 notice that cites 'other' as the principal reason 40% of the time and write the one fact that would move a special-purpose program is for adverse-action notice operations lead.