Assess whether notices match the actual decisioning reasons (198917)

SITUATION Examination and Notices work in an institution preparing for a redlining exam now turns on notices match the actual because an underwriter chat that used coded language put SPCP written plan versus actual originations in play. Fair-lending officer should say what SPCP written plan versus actual originations proves.

DECISION Fair-lending officer 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 SPCP written plan versus actual originations after an underwriter chat that used coded language.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; SPCP written plan versus actual originations already has the discriminator after an underwriter chat that used coded language. 2. Keep Temporary compensating control in force until SPCP written plan versus actual originations is completed after an underwriter chat that used coded language for fair-lending officer. 3. Treat SPCP written plan versus actual originations as Approve a documented exception because both readings appear after an underwriter chat that used coded language. 4. Refuse a Fair Lending close: fair-lending officer does not have the decision notices match the actual turns on in SPCP written plan versus actual originations.

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 an underwriter chat that used coded language. 3. Flag any disparate-impact table fair-lending officer cannot explain from SPCP written plan versus actual originations. 4. For this Fair Lending Examination and Notices file, read SPCP written plan versus actual originations against an underwriter chat that used coded language 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 / Examination and Notices packet (SPCP written plan versus actual originations after an underwriter chat that used coded language). The follow-on Examination and Notices 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 - Examination and Notices finding in SPCP written plan versus actual originations that a second reviewer can re-perform - Missing page in SPCP written plan versus actual originations after an underwriter chat that used coded language, if any