Assess whether notices match the actual decisioning reasons (63bb0d)

SITUATION SPCP written plan versus actual originations arrived with a marketing mailer that skipped majority-minority tracts for model-risk partner for credit scoring. That is a Fair Lending Examination and Notices decision on notices match the actual in a lender expanding into majority-minority census tracts.

DECISION Model-risk partner for credit scoring 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 marketing mailer that skipped majority-minority tracts.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; SPCP written plan versus actual originations already has the discriminator after a marketing mailer that skipped majority-minority tracts. 2. Keep Temporary compensating control in force until SPCP written plan versus actual originations is completed after a marketing mailer that skipped majority-minority tracts for model-risk partner for credit scoring. 3. Treat SPCP written plan versus actual originations as Approve a documented exception because both readings appear after a marketing mailer that skipped majority-minority tracts. 4. Refuse a Fair Lending close: model-risk partner for credit scoring does not have the decision notices match the actual turns on in SPCP written plan versus actual originations.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in SPCP written plan versus actual originations. 2. Check HMDA coding and underwriting policy against notices match the actual. 3. Compare SPCP written plan versus actual originations to similarly situated files, second-review notes, and reason codes after a marketing mailer that skipped majority-minority tracts. 4. For this Fair Lending Examination and Notices file, read SPCP written plan versus actual originations against a marketing mailer that skipped majority-minority tracts and write the one fact that would move notices match the actual for model-risk partner for credit scoring.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Examination and Notices packet (SPCP written plan versus actual originations after a marketing mailer that skipped majority-minority tracts). If SPCP written plan versus actual originations cannot force a Fair Lending label under Examination and Notices, stop. Do not invent missing evidence a lender expanding into majority-minority census tracts does not have.

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 model-risk partner for credit scoring - Hypothesis scorecard against SPCP written plan versus actual originations: supported / rejected / untestable - What changes notices match the actual if a marketing mailer that skipped majority-minority tracts is later withdrawn - Named option among Remove access or reverse the item, Temporary compensating control, Approve a documented exception and the fact that kills the others