Assess whether notices match the actual decisioning reasons (86931a)

SITUATION In a small-business desk using a new vendor score, CRA assessment-area versus lending footprint is the evidence after a board asking if the bank should settle a matched-pair study. Adverse-action notice operations lead has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending CRA and Special-Purpose Programs close using CRA assessment-area versus lending footprint.

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 CRA assessment-area versus lending footprint after a board asking if the bank should settle a matched-pair study.

HYPOTHESES TO TEST 1. CRA assessment-area versus lending footprint reads as Remove access or reverse the item once a board asking if the bank should settle a matched-pair study is lined up to the same Fair Lending population. 2. CRA assessment-area versus lending footprint is closer to Temporary compensating control after a board asking if the bank should settle a matched-pair study; Remove access or reverse the item would over-claim this CRA and Special-Purpose Programs extract. 3. Approve a documented exception is still live in CRA assessment-area versus lending footprint for adverse-action notice operations lead in a small-business desk using a new vendor score. 4. CRA assessment-area versus lending footprint is missing the fact adverse-action notice operations lead needs after a board asking if the bank should settle a matched-pair study; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in CRA assessment-area versus lending footprint. 2. Check HMDA coding and underwriting policy against notices match the actual. 3. Compare CRA assessment-area versus lending footprint to similarly situated files, second-review notes, and reason codes after a board asking if the bank should settle a matched-pair study. 4. For this Fair Lending CRA and Special-Purpose Programs file, read CRA assessment-area versus lending footprint against a board asking if the bank should settle a matched-pair study and write the one fact that would move notices match the actual for adverse-action notice operations lead.

RECOMMENDATION Release Remove access or reverse the item for this Fair Lending CRA and Special-Purpose Programs file only when CRA assessment-area versus lending footprint after a board asking if the bank should settle a matched-pair study names the fact notices match the actual requires. Adverse-action notice operations lead in a small-business desk using a new vendor score should withhold Remove access or reverse the item while that fact is still a hole in CRA assessment-area versus lending footprint.