Assess whether notices match the actual decisioning reasons (9056d2)

SITUATION A board asking if the bank should settle a matched-pair study put SPCP written plan versus actual originations in front of second-review underwriter in a lender expanding into majority-minority census tracts. This Fair Lending / CRA and Special-Purpose Programs close is notices match the actual from SPCP written plan versus actual originations, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

DECISION Second-review underwriter 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 SPCP written plan versus actual originations after a board asking if the bank should settle a matched-pair study.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; SPCP written plan versus actual originations already has the discriminator after a board asking if the bank should settle a matched-pair study. 2. Keep Temporary compensating control in force until SPCP written plan versus actual originations is completed after a board asking if the bank should settle a matched-pair study for second-review underwriter. 3. Treat SPCP written plan versus actual originations as Approve a documented exception because both readings appear after a board asking if the bank should settle a matched-pair study. 4. Refuse a Fair Lending close: second-review underwriter does not have the decision notices match the actual turns on in SPCP written plan versus actual originations.

ANALYSIS REQUIRED 1. Compare SPCP written plan versus actual originations to similarly situated files, second-review notes, and reason codes after a board asking if the bank should settle a matched-pair study. 2. Flag any disparate-impact table second-review underwriter cannot explain from SPCP written plan versus actual originations. 3. Test a documented exception versus a pattern a lender expanding into majority-minority census tracts must defend. 4. For this Fair Lending CRA and Special-Purpose Programs file, read SPCP written plan versus actual originations against a board asking if the bank should settle a matched-pair study and write the one fact that would move notices match the actual for second-review underwriter.

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 board asking if the bank should settle a matched-pair study). The follow-on CRA and Special-Purpose Programs action is what second-review underwriter does next: implement the option, assign an owner, and log the missing fact.