Assess whether notices match the actual decisioning reasons (e7a76c)

SITUATION After a CRA PE that called the assessment area too narrow, SPCP written plan versus actual originations is what model-risk partner for credit scoring can touch in a lender expanding into majority-minority census tracts. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this Examination and Notices file.

DECISION Model-risk partner for credit scoring 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 CRA PE that called the assessment area too narrow.

HYPOTHESES TO TEST 1. SPCP written plan versus actual originations reads as Remove access or reverse the item once a CRA PE that called the assessment area too narrow is lined up to the same Fair Lending population. 2. SPCP written plan versus actual originations is closer to Temporary compensating control after a CRA PE that called the assessment area too narrow; Remove access or reverse the item would over-claim this Examination and Notices extract. 3. Approve a documented exception is still live in SPCP written plan versus actual originations for model-risk partner for credit scoring in a lender expanding into majority-minority census tracts. 4. SPCP written plan versus actual originations is missing the fact model-risk partner for credit scoring needs after a CRA PE that called the assessment area too narrow; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in SPCP written plan versus actual originations. 2. Check HMDA coding and underwriting policy against notices match the actual. 3. Compare SPCP written plan versus actual originations to similarly situated files, second-review notes, and reason codes after a CRA PE that called the assessment area too narrow. 4. For this Fair Lending Examination and Notices file, read SPCP written plan versus actual originations against a CRA PE that called the assessment area too narrow and write the one fact that would move notices match the actual for model-risk partner for credit scoring.

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 a CRA PE that called the assessment area too narrow). Lead with the Fair Lending option SPCP written plan versus actual originations can support after a CRA PE that called the assessment area too narrow, then the two facts that force it, then the Monday action for model-risk partner for credit scoring in a lender expanding into majority-minority census tracts.