Assess whether the exam response should concede a finding (cbd0cf)

SITUATION CRA and Special-Purpose Programs work in an institution preparing for a redlining exam now turns on the exam response should because a SPCP that originated almost no loans to the intended class put SPCP written plan versus actual originations in play. Community-development lender should say what SPCP written plan versus actual originations proves.

DECISION Community-development lender 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 SPCP that originated almost no loans to the intended class.

HYPOTHESES TO TEST 1. The population in SPCP written plan versus actual originations is the one a SPCP that originated almost no loans to the intended class named, so Remove access or reverse the item follows for this CRA and Special-Purpose Programs file. 2. The population in SPCP written plan versus actual originations is adjacent only to a SPCP that originated almost no loans to the intended class; Temporary compensating control is the honest Fair Lending call. 3. An institution preparing for a redlining exam already contained a SPCP that originated almost no loans to the intended class before SPCP written plan versus actual originations arrived; no new CRA and Special-Purpose Programs path. 4. Provenance on SPCP written plan versus actual originations after a SPCP that originated almost no loans to the intended class is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

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 CRA and Special-Purpose Programs file, read SPCP written plan versus actual originations 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 community-development lender.

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 a SPCP that originated almost no loans to the intended class). Lead with the Fair Lending option SPCP written plan versus actual originations 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 community-development lender in an institution preparing for a redlining exam.