Assess whether the exam response should concede a finding (de7b4e)

SITUATION A SPCP that originated almost no loans to the intended class put small-business decline comparative file set in front of adverse-action notice operations lead in a credit-card issuer changing line-assignment logic. This Fair Lending / Examination and Notices decision is the exam response should from small-business decline comparative file set, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

DECISION Adverse-action notice operations lead in a credit-card issuer changing line-assignment logic must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using small-business decline comparative file set after a SPCP that originated almost no loans to the intended class.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; small-business decline comparative file set already has the discriminator after a SPCP that originated almost no loans to the intended class. 2. Keep Temporary compensating control in force until small-business decline comparative file set is completed after a SPCP that originated almost no loans to the intended class for adverse-action notice operations lead. 3. Treat small-business decline comparative file set as Approve a documented exception because both readings appear after a SPCP that originated almost no loans to the intended class. 4. Refuse a Fair Lending close: adverse-action notice operations lead does not have the decision the exam response should turns on in small-business decline comparative file set.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against the exam response should. 2. Compare small-business decline comparative file set to similarly situated files, second-review notes, and reason codes after a SPCP that originated almost no loans to the intended class. 3. Flag any disparate-impact table adverse-action notice operations lead cannot explain from small-business decline comparative file set. 4. For this Fair Lending Examination and Notices file, read small-business decline comparative file set 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 adverse-action notice operations lead.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Examination and Notices packet (small-business decline comparative file set after a SPCP that originated almost no loans to the intended class). If small-business decline comparative file set cannot force a Fair Lending label under Examination and Notices, stop. If small-business decline comparative file set after a SPCP that originated almost no loans to the intended class cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending Examination and Notices close, adverse-action notice operations lead must do not infer a control or scheme beyond the transaction and entitlement evidence.