Assess whether the exam response should concede a finding (38ca80)

SITUATION Underwriting exception log by branch arrived with a SPCP that originated almost no loans to the intended class for exam-response coordinator. That is a Fair Lending Pricing and Credit Limits decision on the exam response should in an institution preparing for a redlining exam.

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 underwriting exception log by branch after a SPCP that originated almost no loans to the intended class.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; underwriting exception log by branch already has the discriminator after a SPCP that originated almost no loans to the intended class. 2. Keep Temporary compensating control in force until underwriting exception log by branch is completed after a SPCP that originated almost no loans to the intended class for exam-response coordinator. 3. Treat underwriting exception log by branch as Approve a documented exception because both readings appear after a SPCP that originated almost no loans to the intended class. 4. Refuse a Fair Lending close: exam-response coordinator does not have the decision the exam response should turns on in underwriting exception log by branch.

ANALYSIS REQUIRED 1. Compare underwriting exception log by branch to similarly situated files, second-review notes, and reason codes after a SPCP that originated almost no loans to the intended class. 2. Flag any disparate-impact table exam-response coordinator cannot explain from underwriting exception log by branch. 3. Test a documented exception versus a pattern an institution preparing for a redlining exam must defend. 4. For this Fair Lending Pricing and Credit Limits file, read underwriting exception log by branch 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 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 (underwriting exception log by branch after a SPCP that originated almost no loans to the intended class). The follow-on Pricing and Credit Limits action is what exam-response coordinator does next: implement the option, assign an owner, and log the missing fact.

COMMAND RETURNS - Bottom-line Fair Lending option on the exam response should, then the evidence in underwriting exception log by branch, then the action for exam-response coordinator - Hypothesis scorecard against underwriting exception log by branch: supported / rejected / untestable - Regulatory or exam hook Pricing and Credit Limits would cite - Pricing and Credit Limits finding in underwriting exception log by branch that a second reviewer can re-perform