Assess whether notices match the actual decisioning reasons (914741)

SITUATION After a notice that cites 'other' as the principal reason 40% of the time, SPCP written plan versus actual originations is what adverse-action notice operations lead can touch in a lender expanding into majority-minority census tracts. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this Redlining and HMDA Data file.

DECISION Adverse-action notice operations lead 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 notice that cites 'other' as the principal reason 40% of the time.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; SPCP written plan versus actual originations already has the discriminator after a notice that cites 'other' as the principal reason 40% of the time. 2. Keep Temporary compensating control in force until SPCP written plan versus actual originations is completed after a notice that cites 'other' as the principal reason 40% of the time for adverse-action notice operations lead. 3. Treat SPCP written plan versus actual originations as Approve a documented exception because both readings appear after a notice that cites 'other' as the principal reason 40% of the time. 4. Refuse a Fair Lending close: adverse-action notice operations lead does not have the decision notices match the actual turns on in SPCP written plan versus actual originations.

ANALYSIS REQUIRED 1. Flag any disparate-impact table adverse-action notice operations lead cannot explain from SPCP written plan versus actual originations. 2. Test a documented exception versus a pattern a lender expanding into majority-minority census tracts must defend. 3. Match the adverse-action language to the facts in SPCP written plan versus actual originations. 4. For this Fair Lending Redlining and HMDA Data file, read SPCP written plan versus actual originations against a notice that cites 'other' as the principal reason 40% of the time and write the one fact that would move notices match the actual for adverse-action notice operations lead.

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 notice that cites 'other' as the principal reason 40% of the time). The follow-on Redlining and HMDA Data action is what adverse-action notice operations lead does next: implement the option, assign an owner, and log the missing fact.