Assess whether line assignments have a disparate impact the bank will defend

SITUATION A notice that cites 'other' as the principal reason 40% of the time put SPCP written plan versus actual originations in front of community-development lender in an institution preparing for a redlining exam. This Fair Lending / CRA and Special-Purpose Programs close is line assignments have a 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 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 notice that cites 'other' as the principal reason 40% of the time.

HYPOTHESES TO TEST 1. A notice that cites 'other' as the principal reason 40% of the time is noise around an already-controlled CRA and Special-Purpose Programs process in an institution preparing for a redlining exam, given SPCP written plan versus actual originations. 2. A notice that cites 'other' as the principal reason 40% of the time is the event in SPCP written plan versus actual originations that forces Remove access or reverse the item for community-development lender under Fair Lending. 3. SPCP written plan versus actual originations shows a one-file miss after a notice that cites 'other' as the principal reason 40% of the time, not a CRA and Special-Purpose Programs program failure. 4. SPCP written plan versus actual originations cannot decide line assignments have a yet after a notice that cites 'other' as the principal reason 40% of the time; hold is the only Fair Lending close an institution preparing for a redlining exam can defend.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against line assignments have a. 2. Compare SPCP written plan versus actual originations to similarly situated files, second-review notes, and reason codes after a notice that cites 'other' as the principal reason 40% of the time. 3. Flag any disparate-impact table community-development lender cannot explain from SPCP written plan versus actual originations. 4. For this Fair Lending CRA and Special-Purpose Programs file, read SPCP written plan versus actual originations against a notice that cites 'other' as the principal reason 40% of the time and write the one fact that would move line assignments have a 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 notice that cites 'other' as the principal reason 40% of the time). Lead with the Fair Lending option SPCP written plan versus actual originations can support after a notice that cites 'other' as the principal reason 40% of the time, then the two facts that force it, then the Monday action for community-development lender in an institution preparing for a redlining exam.