Assess whether a redlining pattern exists after controls (91b867)

Situation

SPCP written plan versus actual originations arrived with a community complaint about appraisal gaps for adverse-action notice operations lead. That is a Fair Lending CRA and Special-Purpose Programs decision on a redlining pattern exists in a small-business desk using a new vendor score.

Decision

Adverse-action notice operations lead in a small-business desk using a new vendor score 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

• A community complaint about appraisal gaps is noise around an already-controlled CRA and Special-Purpose Programs process in a small-business desk using a new vendor score, given SPCP written plan versus actual originations.
• A community complaint about appraisal gaps is the event in SPCP written plan versus actual originations that forces Remove access or reverse the item for adverse-action notice operations lead under Fair Lending.
• SPCP written plan versus actual originations shows a one-file miss after a community complaint about appraisal gaps, not a CRA and Special-Purpose Programs program failure.
• SPCP written plan versus actual originations cannot decide a redlining pattern exists yet after a community complaint about appraisal gaps; hold is the only Fair Lending close a small-business desk using a new vendor score can defend.

Analysis required

• Flag any disparate-impact table adverse-action notice operations lead cannot explain from SPCP written plan versus actual originations.
• Test a documented exception versus a pattern a small-business desk using a new vendor score must defend.
• Match the adverse-action language to the facts in SPCP written plan versus actual originations.
• 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 a redlining pattern exists for adverse-action notice operations lead.

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). Lead with the Fair Lending option SPCP written plan versus actual originations can support after a community complaint about appraisal gaps, then the two facts that force it, then the Monday action for adverse-action notice operations lead in a small-business desk using a new vendor score.