Assess whether notices match the actual decisioning reasons after a SPCP that

SITUATION After a SPCP that originated almost no loans to the intended class, credit-card limit assignment disparity table is the working evidence for CRA strategist in an institution preparing for a redlining exam. Decide whether notices match the actual decisioning reasons using only what credit-card limit assignment disparity table actually supports.

DECISION CRA strategist 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 credit-card limit assignment disparity table after a SPCP that originated almost no loans to the intended class.

HYPOTHESES TO TEST 1. Credit-card limit assignment disparity table reads as Remove access or reverse the item once a SPCP that originated almost no loans to the intended class is lined up to the same Fair Lending population. 2. Credit-card limit assignment disparity table is closer to Temporary compensating control after a SPCP that originated almost no loans to the intended class; Remove access or reverse the item would over-claim this Redlining and HMDA Data extract. 3. Approve a documented exception is still live in credit-card limit assignment disparity table for CRA strategist in an institution preparing for a redlining exam. 4. Credit-card limit assignment disparity table is missing the fact CRA strategist needs after a SPCP that originated almost no loans to the intended class; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against notices match the actual. 2. Compare credit-card limit assignment disparity table 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 CRA strategist cannot explain from credit-card limit assignment disparity table. 4. For this Fair Lending Redlining and HMDA Data file, read credit-card limit assignment disparity table 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 CRA strategist.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Redlining and HMDA Data packet (credit-card limit assignment disparity table after a SPCP that originated almost no loans to the intended class). The follow-on Redlining and HMDA Data action is what CRA strategist does next: implement the option, assign an owner, and log the missing fact.

COMMAND RETURNS - Bottom-line Fair Lending option on notices match the actual, then the evidence in credit-card limit assignment disparity table, then the action for CRA strategist - Hypothesis scorecard against credit-card limit assignment disparity table: supported / rejected / untestable - Owner and next date for CRA strategist in an institution preparing for a redlining exam - What changes notices match the actual if a SPCP that originated almost no loans to the intended class is later withdrawn