ECOA/FCRA adverse-action notice scaffolds + satisfy-timer

Featurekamo-shared-library
Shipped
July 27, 2026 at 7:49 PM UTC
Author
Kamo
Commit
dae26a7

The issuance mechanism's shared-lib half. ComplianceTimerService gains **************** — flips only ARMED ECOA_AA timers to SATISFIED (leaves COUNTEROFFER/INCOMPLETE_NOA and already-satisfied untouched), so a SENT adverse-action notice can close the Reg B clock while an un-sent one stays ARMED for the breach sweep. Two canonical email templates — ADVERSE_ACTION_NOTICE (ECOA/Reg B + FCRA §615(a)) and RISK_BASED_PRICING_NOTICE (FCRA §615(h)/Reg V) — registered in CanonicalTemplateLoader. Both are STRUCTURAL scaffolds only: a dashed [[ YOUR COMPLIANCE-APPROVED ... ]] placeholder the creditor's counsel fills in, plus structured-data variables (applicant, date, principal reasons / trigger). Kamo supplies no operative legal notice prose.

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