Assess whether notices match the actual decisioning reasons (07b222)

SITUATION After a SPCP that originated almost no loans to the intended class, adverse-action notice principal-reason sample is what exam-response coordinator can touch in a mortgage company after a pricing-regression spike. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this Examination and Notices file.

DECISION Exam-response coordinator in a mortgage company after a pricing-regression spike must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using adverse-action notice principal-reason sample after a SPCP that originated almost no loans to the intended class.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; adverse-action notice principal-reason sample already has the discriminator after a SPCP that originated almost no loans to the intended class. 2. Keep Temporary compensating control in force until adverse-action notice principal-reason sample is completed after a SPCP that originated almost no loans to the intended class for exam-response coordinator. 3. Treat adverse-action notice principal-reason sample 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 notices match the actual turns on in adverse-action notice principal-reason sample.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against notices match the actual. 2. Compare adverse-action notice principal-reason sample to similarly situated files, second-review notes, and reason codes after a SPCP that originated almost no loans to the intended class. 3. Flag any disparate-impact table exam-response coordinator cannot explain from adverse-action notice principal-reason sample. 4. For this Fair Lending Examination and Notices file, read adverse-action notice principal-reason sample against a SPCP that originated almost no loans to the intended class and write the one fact that would move notices match the actual for exam-response coordinator.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Examination and Notices packet (adverse-action notice principal-reason sample after a SPCP that originated almost no loans to the intended class). If adverse-action notice principal-reason sample cannot force a Fair Lending label under Examination and Notices, stop. If adverse-action notice principal-reason sample after a SPCP that originated almost no loans to the intended class cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending Examination and Notices close, exam-response coordinator must do not infer a control or scheme beyond the transaction and entitlement evidence.