Assess whether notices match the actual decisioning reasons from SPCP written

SITUATION Community-development lender in a mortgage company after a pricing-regression spike has one working extract — SPCP written plan versus actual originations — after a branch that stopped taking applications in one ZIP. If SPCP written plan versus actual originations cannot support notices match the actual, the only defensible Fair Lending output is hold.

DECISION Community-development lender in a mortgage company after a pricing-regression spike 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 branch that stopped taking applications in one ZIP.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; SPCP written plan versus actual originations already has the discriminator after a branch that stopped taking applications in one ZIP. 2. Keep Temporary compensating control in force until SPCP written plan versus actual originations is completed after a branch that stopped taking applications in one ZIP for community-development lender. 3. Treat SPCP written plan versus actual originations as Approve a documented exception because both readings appear after a branch that stopped taking applications in one ZIP. 4. Refuse a Fair Lending close: community-development lender does not have the decision notices match the actual turns on in SPCP written plan versus actual originations.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern a mortgage company after a pricing-regression spike must defend. 2. Match the adverse-action language to the facts in SPCP written plan versus actual originations. 3. Check HMDA coding and underwriting policy against notices match the actual. 4. For this Fair Lending Redlining and HMDA Data file, read SPCP written plan versus actual originations against a branch that stopped taking applications in one ZIP 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 / Redlining and HMDA Data packet (SPCP written plan versus actual originations after a branch that stopped taking applications in one ZIP). The follow-on Redlining and HMDA Data action is what community-development lender 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 SPCP written plan versus actual originations, then the action for community-development lender - Hypothesis scorecard against SPCP written plan versus actual originations: supported / rejected / untestable - Missing page in SPCP written plan versus actual originations after a branch that stopped taking applications in one ZIP, if any - Regulatory or exam hook Redlining and HMDA Data would cite