Assess whether the exam response should concede a finding (7c556b)

SITUATION In a bank with thin HMDA LAR quality, SPCP written plan versus actual originations is the evidence after an exception rate twice as high for one group after credit controls. Fair-lending officer has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending CRA and Special-Purpose Programs close using SPCP written plan versus actual originations.

DECISION Fair-lending officer in a bank with thin HMDA LAR quality must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using SPCP written plan versus actual originations after an exception rate twice as high for one group after credit controls.

HYPOTHESES TO TEST 1. SPCP written plan versus actual originations reads as Remove access or reverse the item once an exception rate twice as high for one group after credit controls is lined up to the same Fair Lending population. 2. SPCP written plan versus actual originations is closer to Temporary compensating control after an exception rate twice as high for one group after credit controls; Remove access or reverse the item would over-claim this CRA and Special-Purpose Programs extract. 3. Approve a documented exception is still live in SPCP written plan versus actual originations for fair-lending officer in a bank with thin HMDA LAR quality. 4. SPCP written plan versus actual originations is missing the fact fair-lending officer needs after an exception rate twice as high for one group after credit controls; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in SPCP written plan versus actual originations. 2. Check HMDA coding and underwriting policy against the exam response should. 3. Compare SPCP written plan versus actual originations to similarly situated files, second-review notes, and reason codes after an exception rate twice as high for one group after credit controls. 4. For this Fair Lending CRA and Special-Purpose Programs file, read SPCP written plan versus actual originations against an exception rate twice as high for one group after credit controls 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 / CRA and Special-Purpose Programs packet (SPCP written plan versus actual originations after an exception rate twice as high for one group after credit controls). Lead with the Fair Lending option SPCP written plan versus actual originations can support after an exception rate twice as high for one group after credit controls, then the two facts that force it, then the Monday action for fair-lending officer in a bank with thin HMDA LAR quality.