Assess whether the exam response should concede a finding (87917b)

SITUATION Fair-lending officer is responsible for the exam response should in an institution preparing for a redlining exam, using model-reason-code mapping that does not match notices as the only working extract. A SPCP that originated almost no loans to the intended class is what reset the timeline for this Fair Lending Examination and Notices file.

DECISION Fair-lending officer in an institution preparing for a redlining exam must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using model-reason-code mapping that does not match notices after a SPCP that originated almost no loans to the intended class.

HYPOTHESES TO TEST 1. Fair-lending officer can defend Remove access or reverse the item from model-reason-code mapping that does not match notices after a SPCP that originated almost no loans to the intended class in a Fair Lending challenge. 2. Fair-lending officer cannot defend Remove access or reverse the item from model-reason-code mapping that does not match notices; Temporary compensating control is what the extract actually supports after a SPCP that originated almost no loans to the intended class. 3. A SPCP that originated almost no loans to the intended class never reached the population in model-reason-code mapping that does not match notices — reopen intake, do not close the exam response should. 4. Two facts in model-reason-code mapping that does not match notices after a SPCP that originated almost no loans to the intended class conflict for fair-lending officer; hold this Examination and Notices file.

ANALYSIS REQUIRED 1. Compare model-reason-code mapping that does not match notices to similarly situated files, second-review notes, and reason codes after a SPCP that originated almost no loans to the intended class. 2. Flag any disparate-impact table fair-lending officer cannot explain from model-reason-code mapping that does not match notices. 3. Test a documented exception versus a pattern an institution preparing for a redlining exam must defend. 4. For this Fair Lending Examination and Notices file, read model-reason-code mapping that does not match notices against a SPCP that originated almost no loans to the intended class and write the one fact that would move the exam response should for fair-lending officer.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Examination and Notices packet (model-reason-code mapping that does not match notices after a SPCP that originated almost no loans to the intended class). Lead with the Fair Lending option model-reason-code mapping that does not match notices can support after a SPCP that originated almost no loans to the intended class, then the two facts that force it, then the Monday action for fair-lending officer in an institution preparing for a redlining exam.