Assess whether notices match the actual decisioning reasons (cc3992)

SITUATION After a vendor score change with no disparate-impact test, geographic application and origination heat map is what CRA strategist can touch in an institution preparing for a redlining exam. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this Redlining and HMDA Data file.

DECISION CRA strategist in an institution preparing for a redlining exam must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using geographic application and origination heat map after a vendor score change with no disparate-impact test.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; geographic application and origination heat map already has the discriminator after a vendor score change with no disparate-impact test. 2. Keep Temporary compensating control in force until geographic application and origination heat map is completed after a vendor score change with no disparate-impact test for CRA strategist. 3. Treat geographic application and origination heat map as Approve a documented exception because both readings appear after a vendor score change with no disparate-impact test. 4. Refuse a Fair Lending close: CRA strategist does not have the decision notices match the actual turns on in geographic application and origination heat map.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against notices match the actual. 2. Compare geographic application and origination heat map to similarly situated files, second-review notes, and reason codes after a vendor score change with no disparate-impact test. 3. Flag any disparate-impact table CRA strategist cannot explain from geographic application and origination heat map. 4. For this Fair Lending Redlining and HMDA Data file, read geographic application and origination heat map against a vendor score change with no disparate-impact test and write the one fact that would move notices match the actual for CRA strategist.

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 (geographic application and origination heat map after a vendor score change with no disparate-impact test). The follow-on Redlining and HMDA Data action is what CRA strategist 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 geographic application and origination heat map, then the action for CRA strategist - Hypothesis scorecard against geographic application and origination heat map: supported / rejected / untestable - Owner and next date for CRA strategist in an institution preparing for a redlining exam - What changes notices match the actual if a vendor score change with no disparate-impact test is later withdrawn