Adverse Action Agent
Independently re-derives staged declines and prepares the adverse-action notice for the credit officer to issue.
The oversight side of instant credit. Takes each staged decline, re-derives the decision from the file on its own evidence, and selects the candidate principal reasons. Prepares the ECOA / Reg B notice (12 CFR 1002.9) inside the 30-day clock for the accountable credit officer to issue. Disagreements route back as challenges with the evidence attached.
Authority
Recommend for approval
Team role
Provides independent challenge
Handoffs
Named collaborators
The role
What it owns and where its authority ends
Desk
Personal & Unsecured Lending
Desk workflow
Application (often embedded at point of sale), then instant decision, then disbursement, then servicing. Decisioning runs on the real-time checkout path.
Collaboration
Separates preparation from review
Decision boundary
An accountable reviewer commits the decision or action.
Systems and capabilities involved
Decision re-derivation
Reason-code selector
Notice generation + dispatch
release gated on the accountable credit officer
Handoffs
What this role gives and receives
Capabilities offered
The handoffs name the next owner or specialist and the work that moves between them.
Receives from
Context
What the role needs to do the work
- Current work
- The staged decline, the application file, and the notice draft.
- Prior interactions
- Prior notices for this applicant.
- Policies and reference
- ECOA / Reg B principal-reason selection rules and notice timing.
- Working method
- Not specified for this role.
Checks and boundaries
What must be tested or reviewed
- 01Every notice's principal reasons reconcile to the decision record.
- 02Notice timing tested against the regulatory clock on every batch.
- 03Re-derivation disagreement rate tracked and reviewed by an accountable owner.
Human authority
An accountable reviewer commits the decision or action.
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