Assess whether a redlining pattern exists after controls (0ef00f)

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 a redlining pattern exists 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

• 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.
• 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.
• 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.
• SPCP written plan versus actual originations cannot decide a redlining pattern exists 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

• Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend.
• 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.
• 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 a redlining pattern exists 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). If SPCP written plan versus actual originations cannot force a Fair Lending label under CRA and Special-Purpose Programs, stop. If SPCP written plan versus actual originations after a vendor score change with no disparate-impact test cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending CRA and Special-Purpose Programs close, fair-lending officer must do not infer a control or scheme beyond the transaction and entitlement evidence.