Assess whether notices match the actual decisioning reasons (429e5e)

SITUATION In an institution preparing for a redlining exam, small-business decline comparative file set is the evidence after a vendor score change with no disparate-impact test. Community-development lender has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending CRA and Special-Purpose Programs close using small-business decline comparative file set.

DECISION Community-development lender 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 small-business decline comparative file set after a vendor score change with no disparate-impact test.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; small-business decline comparative file set already has the discriminator after a vendor score change with no disparate-impact test. 2. Keep Temporary compensating control in force until small-business decline comparative file set is completed after a vendor score change with no disparate-impact test for community-development lender. 3. Treat small-business decline comparative file set 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: community-development lender does not have the decision notices match the actual turns on in small-business decline comparative file set.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern an institution preparing for a redlining exam must defend. 2. Match the adverse-action language to the facts in small-business decline comparative file set. 3. Check HMDA coding and underwriting policy against notices match the actual. 4. For this Fair Lending CRA and Special-Purpose Programs file, read small-business decline comparative file set against a vendor score change with no disparate-impact test and write the one fact that would move notices match the actual for community-development lender.

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 (small-business decline comparative file set after a vendor score change with no disparate-impact test). Lead with the Fair Lending option small-business decline comparative file set can support after a vendor score change with no disparate-impact test, then the two facts that force it, then the Monday action for community-development lender in an institution preparing for a redlining exam.

COMMAND RETURNS - Bottom-line Fair Lending option on notices match the actual, then the evidence in small-business decline comparative file set, then the action for community-development lender - Hypothesis scorecard against small-business decline comparative file set: supported / rejected / untestable - Regulatory or exam hook CRA and Special-Purpose Programs would cite - CRA and Special-Purpose Programs finding in small-business decline comparative file set that a second reviewer can re-perform