Assess whether notices match the actual decisioning reasons (6520a9)

SITUATION SPCP written plan versus actual originations arrived with a vendor score change with no disparate-impact test for fair-lending officer. That is a Fair Lending CRA and Special-Purpose Programs decision on notices match the actual in a bank with thin HMDA LAR quality.

DECISION Fair-lending officer in a bank with thin HMDA LAR quality 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 vendor score change with no disparate-impact test.

HYPOTHESES TO TEST 1. A vendor score change with no disparate-impact test is noise around an already-controlled CRA and Special-Purpose Programs process in a bank with thin HMDA LAR quality, given SPCP written plan versus actual originations. 2. A vendor score change with no disparate-impact test is the event in SPCP written plan versus actual originations that forces Remove access or reverse the item for fair-lending officer under Fair Lending. 3. SPCP written plan versus actual originations shows a one-file miss after a vendor score change with no disparate-impact test, not a CRA and Special-Purpose Programs program failure. 4. SPCP written plan versus actual originations cannot decide notices match the actual yet after a vendor score change with no disparate-impact test; hold is the only Fair Lending close a bank with thin HMDA LAR quality can defend.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against notices match the actual. 2. Compare SPCP written plan versus actual originations to similarly situated files, second-review notes, and reason codes after a vendor score change with no disparate-impact test. 3. Flag any disparate-impact table fair-lending officer 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 vendor score change with no disparate-impact test and write the one fact that would move notices match the actual for fair-lending officer.

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 vendor score change with no disparate-impact test). The follow-on CRA and Special-Purpose Programs action is what fair-lending officer 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 SPCP written plan versus actual originations, then the action for fair-lending officer - Hypothesis scorecard against SPCP written plan versus actual originations: supported / rejected / untestable - Regulatory or exam hook CRA and Special-Purpose Programs would cite - CRA and Special-Purpose Programs finding in SPCP written plan versus actual originations that a second reviewer can re-perform