Assess whether notices match the actual decisioning reasons (98e3a9)

SITUATION CRA and Special-Purpose Programs work in a lender expanding into majority-minority census tracts now turns on notices match the actual because a community complaint about appraisal gaps put SPCP written plan versus actual originations in play. CRA and Special-Purpose Programs work in a lender expanding into majority-minority census tracts now turns on notices match the actual because a community complaint about appraisal gaps put SPCP written plan versus actual originations in play; second-review underwriter should say what SPCP written plan versus actual originations proves for Fair Lending.

DECISION Second-review underwriter in a lender expanding into majority-minority census tracts 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 community complaint about appraisal gaps.

HYPOTHESES TO TEST 1. Second-review underwriter can defend Remove access or reverse the item from SPCP written plan versus actual originations after a community complaint about appraisal gaps in a Fair Lending challenge. 2. Second-review underwriter cannot defend Remove access or reverse the item from SPCP written plan versus actual originations; Temporary compensating control is what the extract actually supports after a community complaint about appraisal gaps. 3. A community complaint about appraisal gaps never reached the population in SPCP written plan versus actual originations — reopen intake, do not close notices match the actual. 4. Two facts in SPCP written plan versus actual originations after a community complaint about appraisal gaps conflict for second-review underwriter; hold this CRA and Special-Purpose Programs file.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern a lender expanding into majority-minority census tracts must defend. 2. Match the adverse-action language to the facts in SPCP written plan versus actual originations. 3. Check HMDA coding and underwriting policy against notices match the actual. 4. For this Fair Lending CRA and Special-Purpose Programs file, read SPCP written plan versus actual originations against a community complaint about appraisal gaps and write the one fact that would move notices match the actual for second-review underwriter.

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 community complaint about appraisal gaps). If SPCP written plan versus actual originations cannot force a Fair Lending label under CRA and Special-Purpose Programs, stop. If SPCP written plan versus actual originations after a community complaint about appraisal gaps cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending CRA and Special-Purpose Programs close, second-review underwriter must do not infer a control or scheme beyond the transaction and entitlement evidence.