Whether HMDA data can be relied on for the exam from SPCP written plan versus

Situation

The desk packet is SPCP written plan versus actual originations after a CRA PE that called the assessment area too narrow. Adverse-action notice operations lead in a credit union rolling out a special-purpose credit program has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending Pricing and Credit Limits file.

Decision

Adverse-action notice operations lead in a credit union rolling out a special-purpose credit program 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

• SPCP written plan versus actual originations reads as Remove access or reverse the item once a CRA PE that called the assessment area too narrow is lined up to the same Fair Lending population.
• SPCP written plan versus actual originations is closer to Temporary compensating control after a CRA PE that called the assessment area too narrow; Remove access or reverse the item would over-claim this Pricing and Credit Limits extract.
• Approve a documented exception is still live in SPCP written plan versus actual originations for adverse-action notice operations lead in a credit union rolling out a special-purpose credit program.
• SPCP written plan versus actual originations is missing the fact adverse-action notice operations lead needs after a CRA PE that called the assessment area too narrow; stop this Fair Lending close.

Analysis required

• Match the adverse-action language to the facts in SPCP written plan versus actual originations.
• Check HMDA coding and underwriting policy against HMDA data can be relied on.
• Compare SPCP written plan versus actual originations to similarly situated files, second-review notes, and reason codes after a CRA PE that called the assessment area too narrow.
• 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 HMDA data can be relied on 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 / 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. If SPCP written plan versus actual originations after a CRA PE that called the assessment area too narrow cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending Pricing and Credit Limits close, adverse-action notice operations lead must do not infer a control or scheme beyond the transaction and entitlement evidence.