Assess whether the exam response should concede a finding (079cb9)

SITUATION Fair-lending officer owns this Examination and Notices review in an institution preparing for a redlining exam. A branch that stopped taking applications in one ZIP is the triggering event; SPCP written plan versus actual originations is the evidence for whether the exam response should concede a finding.

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 SPCP written plan versus actual originations after a branch that stopped taking applications in one ZIP.

HYPOTHESES TO TEST 1. SPCP written plan versus actual originations reads as Remove access or reverse the item once a branch that stopped taking applications in one ZIP is lined up to the same Fair Lending population. 2. SPCP written plan versus actual originations is closer to Temporary compensating control after a branch that stopped taking applications in one ZIP; Remove access or reverse the item would over-claim this Examination and Notices extract. 3. Approve a documented exception is still live in SPCP written plan versus actual originations for fair-lending officer in an institution preparing for a redlining exam. 4. SPCP written plan versus actual originations is missing the fact fair-lending officer needs after a branch that stopped taking applications in one ZIP; 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 a branch that stopped taking applications in one ZIP. 4. For this Fair Lending Examination and Notices file, read SPCP written plan versus actual originations against a branch that stopped taking applications in one ZIP 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 (SPCP written plan versus actual originations after a branch that stopped taking applications in one ZIP). Lead with the Fair Lending option SPCP written plan versus actual originations can support after a branch that stopped taking applications in one ZIP, then the two facts that force it, then the Monday action for fair-lending officer in an institution preparing for a redlining exam.

COMMAND RETURNS - Bottom-line Fair Lending option on the exam response should, then the evidence in SPCP written plan versus actual originations, then the action for fair-lending officer - Hypothesis scorecard against SPCP written plan versus actual originations: supported / rejected / untestable - What changes the exam response should if a branch that stopped taking applications in one ZIP is later withdrawn - Named option among Remove access or reverse the item, Temporary compensating control, Approve a documented exception and the fact that kills the others