Whether a redlining pattern exists after controls from SPCP written plan

Situation

Redlining and HMDA Data work in a bank with thin HMDA LAR quality now turns on a redlining pattern exists because an exception rate twice as high for one group after credit controls put SPCP written plan versus actual originations in play. Exam-response coordinator should say what SPCP written plan versus actual originations proves.

Decision

Exam-response coordinator 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 an exception rate twice as high for one group after credit controls.

Hypotheses to test

• SPCP written plan versus actual originations reads as Remove access or reverse the item once an exception rate twice as high for one group after credit controls is lined up to the same Fair Lending population.
• SPCP written plan versus actual originations is closer to Temporary compensating control after an exception rate twice as high for one group after credit controls; Remove access or reverse the item would over-claim this Redlining and HMDA Data extract.
• Approve a documented exception is still live in SPCP written plan versus actual originations for exam-response coordinator in a bank with thin HMDA LAR quality.
• SPCP written plan versus actual originations is missing the fact exam-response coordinator needs after an exception rate twice as high for one group after credit controls; stop this Fair Lending close.

Analysis required

• Match the adverse-action language to the facts in SPCP written plan versus actual originations.
• Check HMDA coding and underwriting policy against a redlining pattern exists.
• Compare SPCP written plan versus actual originations to similarly situated files, second-review notes, and reason codes after an exception rate twice as high for one group after credit controls.
• For this Fair Lending Redlining and HMDA Data file, read SPCP written plan versus actual originations against an exception rate twice as high for one group after credit controls and write the one fact that would move a redlining pattern exists for exam-response coordinator.

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 (SPCP written plan versus actual originations after an exception rate twice as high for one group after credit controls). The follow-on Redlining and HMDA Data action is what exam-response coordinator does next: implement the option, assign an owner, and log the missing fact.