Assess whether notices match the actual decisioning reasons (337d16)

SITUATION Model-risk partner for credit scoring is responsible for notices match the actual in a lender expanding into majority-minority census tracts, using appraisal-gap outcomes in majority-minority tracts as the only working extract. A CRA PE that called the assessment area too narrow is what reset the timeline for this Fair Lending 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 appraisal-gap outcomes in majority-minority tracts after a CRA PE that called the assessment area too narrow.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; appraisal-gap outcomes in majority-minority tracts already has the discriminator after a CRA PE that called the assessment area too narrow. 2. Keep Temporary compensating control in force until appraisal-gap outcomes in majority-minority tracts is completed after a CRA PE that called the assessment area too narrow for model-risk partner for credit scoring. 3. Treat appraisal-gap outcomes in majority-minority tracts as Approve a documented exception because both readings appear after a CRA PE that called the assessment area too narrow. 4. Refuse a Fair Lending close: model-risk partner for credit scoring does not have the decision notices match the actual turns on in appraisal-gap outcomes in majority-minority tracts.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against notices match the actual. 2. Compare appraisal-gap outcomes in majority-minority tracts to similarly situated files, second-review notes, and reason codes after a CRA PE that called the assessment area too narrow. 3. Flag any disparate-impact table model-risk partner for credit scoring cannot explain from appraisal-gap outcomes in majority-minority tracts. 4. For this Fair Lending Examination and Notices file, read appraisal-gap outcomes in majority-minority tracts 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 (appraisal-gap outcomes in majority-minority tracts after a CRA PE that called the assessment area too narrow). The follow-on Examination and Notices action is what model-risk partner for credit scoring 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 appraisal-gap outcomes in majority-minority tracts, then the action for model-risk partner for credit scoring - Hypothesis scorecard against appraisal-gap outcomes in majority-minority tracts: supported / rejected / untestable - Regulatory or exam hook Examination and Notices would cite - Examination and Notices finding in appraisal-gap outcomes in majority-minority tracts that a second reviewer can re-perform