Whether the exam response should concede a finding from SPCP written plan

SITUATION Exam-response coordinator is responsible for the exam response should in an institution preparing for a redlining exam, using SPCP written plan versus actual originations as the only working extract. A CRA PE that called the assessment area too narrow is what reset the timeline for this Fair Lending Pricing and Credit Limits file.

DECISION Exam-response coordinator 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 CRA PE that called the assessment area too narrow.

HYPOTHESES TO TEST 1. Exam-response coordinator can defend Remove access or reverse the item from SPCP written plan versus actual originations after a CRA PE that called the assessment area too narrow in a Fair Lending challenge. 2. Exam-response coordinator cannot defend Remove access or reverse the item from SPCP written plan versus actual originations; Temporary compensating control is what the extract actually supports after a CRA PE that called the assessment area too narrow. 3. A CRA PE that called the assessment area too narrow never reached the population in SPCP written plan versus actual originations — reopen intake, do not close the exam response should. 4. Two facts in SPCP written plan versus actual originations after a CRA PE that called the assessment area too narrow conflict for exam-response coordinator; hold this Pricing and Credit Limits file.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern an institution preparing for a redlining exam must defend. 2. Match the adverse-action language to the facts in SPCP written plan versus actual originations. 3. Check HMDA coding and underwriting policy against the exam response should. 4. For this Fair Lending Pricing and Credit Limits file, read SPCP written plan versus actual originations against a CRA PE that called the assessment area too narrow and write the one fact that would move the exam response should for exam-response coordinator.

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 CRA PE that called the assessment area too narrow). If SPCP written plan versus actual originations cannot force a Fair Lending label under Pricing and Credit Limits, stop. Do not invent missing evidence an institution preparing for a redlining exam does not have.

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 exam-response coordinator - Hypothesis scorecard against SPCP written plan versus actual originations: supported / rejected / untestable - Regulatory or exam hook Pricing and Credit Limits would cite - Pricing and Credit Limits finding in SPCP written plan versus actual originations that a second reviewer can re-perform