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Adverse-action reasons

Cadre pack · Grounds

Drafts candidate decision reasons and records supplied score-disclosure fields for accountable review.

Demonstrated on representative cases. Source coverage, thresholds, policy interpretation, escalation design, and performance require institution-specific validation.

Operating dossier

The job, permitted decisions, and owner

Mandate

Determines the specific principal reasons for adverse action under Reg B / FCRA.

Case arrives with
Decision · Application · Decision · Product · Decision · Decision · Decision · Score band
Allowed outcomes
Decline · Counteroffer
Where it fits
Application to Decision
Decision logic
  1. 01Uses the supplied decision and policy configuration to draft candidate principal reasons after a decline or unaccepted counteroffer, including score-disclosure fields when configured.
  2. 02Each candidate reason must trace to a factor the decision actually used; the pack does not invent, soften, or replace it with a generic placeholder.
  3. 03The illustrated review rule favors specific recorded factors, such as a score below the program minimum, over unnamed internal standards.
  4. 04If a prohibited-basis field appears in the decision, the pack surfaces that as a defect for review rather than converting it into an applicant-facing reason.
  5. 05Retains the cited regulation text with its work so an accountable reviewer can confirm that the current rule applies and the draft is complete.
Must not
Use protected-basis fields in the decision path.
Human owner
Incomplete reasons or notice exceptions
Evidence retained
Structured outcome, observed path, and the source evidence used.

Case and record

One case, from supplied evidence to recorded decision

Supplied case

Representative case dataSynthetic or simulated data
Decision · Application
L2
Decision · Product
auto
Decision · Decision
decline
Decision · Score band
below subprime
Decision · Dti pct
35
Decision · Ltv pct
126
Decision · Policy basis
score 561 below the auto minimum of 600, LTV 126% above the 125% maximum
Decision · Factors
credit score below the program minimum, a recent charge-off and a collection, very high revolving utilization (88%)
Decision · Confidence
0.95
View the case data

Case key L2-decline

{
  "decision": {
    "applicationId": "L2",
    "product": "auto",
    "decision": "decline",
    "scoreBand": "below-subprime",
    "dtiPct": 35,
    "ltvPct": 126,
    "policyBasis": [
      "score 561 below the auto minimum of 600",
      "LTV 126% above the 125% maximum"
    ],
    "factors": [
      "credit score below the program minimum",
      "a recent charge-off and a collection",
      "very high revolving utilization (88%)"
    ],
    "confidence": 0.95
  }
}

Evaluation and limits

Evaluation coverage and stopping points

Published evaluation map

Expected decisions, boundaries, and costly failure modes.

These cases show what the pack is asked to decide, when it should stop, and which plausible errors the evaluation is meant to expose. They are not a reliability score or independent validation.

Expected and borderline behavior

Routine judgments, close calls, and named stopping points.

  • subprime auto decline

    principal reasons from score/derogatory/utilization, cites 1002.9

    Case key

    L2-decline
  • card decline

    principal reasons from score/utilization/delinquency, cites 1002.9

    Case key

    L8-card-decline

Operating fit

Workflow placement and validation

Operating pattern

Draft, check, revise

Separate drafting from checking and stop when the work meets clear requirements—or when the agreed review limit is reached.

Decision sequence and workflow placement
  1. 01Draft from evidence
  2. 02Check named requirements
  3. 03Return specific gaps
  4. 04Revise
  5. 05Complete or refer
Pattern guide

Institution-specific validation

These questions remain open until the pack is fitted to an institution.

Validation questions
  • Policy and legal interpretation
  • Source coverage, quality, and freshness
  • Thresholds and exception calibration
  • Integration and degraded-mode behavior
  • Human approval and escalation design
  • Performance on the institution’s own case mix
Inputs, actions, and outcomes
Give it
  • Decision · Application
  • Decision · Product
  • Decision · Decision
  • Decision · Score band
  • Decision · Dti pct
  • Decision · Ltv pct
  • Decision · Policy basis
  • Decision · Factors
  • Decision · Confidence
It does
  • Get credit reportget_credit_report
  • Retrieve regretrieve_reg
  • Record reasonscommitrecord_reasons
It returns · Action taken
  • Decline
  • Counteroffer
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