Assess whether comparative files show second-review bias from SPCP written

SITUATION The working file is SPCP written plan versus actual originations after a marketing mailer that skipped majority-minority tracts. HMDA data-quality manager in a lender expanding into majority-minority census tracts has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending Pricing and Credit Limits file.

DECISION HMDA data-quality manager in a lender expanding into majority-minority census tracts must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using SPCP written plan versus actual originations after a marketing mailer that skipped majority-minority tracts.

HYPOTHESES TO TEST 1. A marketing mailer that skipped majority-minority tracts is noise around an already-controlled Pricing and Credit Limits process in a lender expanding into majority-minority census tracts, given SPCP written plan versus actual originations. 2. A marketing mailer that skipped majority-minority tracts is the event in SPCP written plan versus actual originations that forces Remove access or reverse the item for HMDA data-quality manager under Fair Lending. 3. SPCP written plan versus actual originations shows a one-file miss after a marketing mailer that skipped majority-minority tracts, not a Pricing and Credit Limits program failure. 4. SPCP written plan versus actual originations cannot decide comparative files show second-review yet after a marketing mailer that skipped majority-minority tracts; hold is the only Fair Lending close a lender expanding into majority-minority census tracts can defend.

ANALYSIS REQUIRED 1. Compare SPCP written plan versus actual originations to similarly situated files, second-review notes, and reason codes after a marketing mailer that skipped majority-minority tracts. 2. Flag any disparate-impact table HMDA data-quality manager cannot explain from SPCP written plan versus actual originations. 3. Test a documented exception versus a pattern a lender expanding into majority-minority census tracts must defend. 4. For this Fair Lending Pricing and Credit Limits file, read SPCP written plan versus actual originations against a marketing mailer that skipped majority-minority tracts and write the one fact that would move comparative files show second-review for HMDA data-quality manager.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Pricing and Credit Limits packet (SPCP written plan versus actual originations after a marketing mailer that skipped majority-minority tracts). The follow-on Pricing and Credit Limits action is what HMDA data-quality manager does next: implement the option, assign an owner, and log the missing fact.