Assess whether the exam response should concede a finding (aff3fb)

SITUATION A community complaint about appraisal gaps put SPCP written plan versus actual originations in front of adverse-action notice operations lead in a small-business desk using a new vendor score. This Fair Lending / CRA and Special-Purpose Programs decision is the exam response should from SPCP written plan versus actual originations, 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 small-business desk using a new vendor score 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 community complaint about appraisal gaps.

HYPOTHESES TO TEST 1. A community complaint about appraisal gaps is noise around an already-controlled CRA and Special-Purpose Programs process in a small-business desk using a new vendor score, given SPCP written plan versus actual originations. 2. A community complaint about appraisal gaps is the event in SPCP written plan versus actual originations that forces Remove access or reverse the item for adverse-action notice operations lead under Fair Lending. 3. SPCP written plan versus actual originations shows a one-file miss after a community complaint about appraisal gaps, not a CRA and Special-Purpose Programs program failure. 4. SPCP written plan versus actual originations cannot decide the exam response should yet after a community complaint about appraisal gaps; hold is the only Fair Lending close a small-business desk using a new vendor score can defend.

ANALYSIS REQUIRED 1. Compare SPCP written plan versus actual originations to similarly situated files, second-review notes, and reason codes after a community complaint about appraisal gaps. 2. Flag any disparate-impact table adverse-action notice operations lead cannot explain from SPCP written plan versus actual originations. 3. Test a documented exception versus a pattern a small-business desk using a new vendor score must defend. 4. For this Fair Lending CRA and Special-Purpose Programs file, read SPCP written plan versus actual originations against a community complaint about appraisal gaps 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 / CRA and Special-Purpose Programs packet (SPCP written plan versus actual originations after a community complaint about appraisal gaps). If SPCP written plan versus actual originations cannot force a Fair Lending label under CRA and Special-Purpose Programs, stop. If SPCP written plan versus actual originations after a community complaint about appraisal gaps cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending CRA and Special-Purpose Programs close, adverse-action notice operations lead must do not infer a control or scheme beyond the transaction and entitlement evidence.