Assess whether notices match the actual decisioning reasons (bf722a)

SITUATION SPCP written plan versus actual originations arrived with an exception rate twice as high for one group after credit controls for adverse-action notice operations lead. That is a Fair Lending CRA and Special-Purpose Programs decision on notices match the actual in a small-business desk using a new vendor score.

DECISION Adverse-action notice operations lead in a small-business desk using a new vendor score must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using SPCP written plan versus actual originations after an exception rate twice as high for one group after credit controls.

HYPOTHESES TO TEST 1. SPCP written plan versus actual originations reads as Remove access or reverse the item once an exception rate twice as high for one group after credit controls is lined up to the same Fair Lending population. 2. SPCP written plan versus actual originations is closer to Temporary compensating control after an exception rate twice as high for one group after credit controls; Remove access or reverse the item would over-claim this CRA and Special-Purpose Programs extract. 3. Approve a documented exception is still live in SPCP written plan versus actual originations for adverse-action notice operations lead in a small-business desk using a new vendor score. 4. SPCP written plan versus actual originations is missing the fact adverse-action notice operations lead needs after an exception rate twice as high for one group after credit controls; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Compare SPCP written plan versus actual originations to similarly situated files, second-review notes, and reason codes after an exception rate twice as high for one group after credit controls. 2. Flag any disparate-impact table adverse-action notice operations lead cannot explain from SPCP written plan versus actual originations. 3. Test a documented exception versus a pattern a small-business desk using a new vendor score must defend. 4. For this Fair Lending CRA and Special-Purpose Programs file, read SPCP written plan versus actual originations against an exception rate twice as high for one group after credit controls 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 / CRA and Special-Purpose Programs packet (SPCP written plan versus actual originations after an exception rate twice as high for one group after credit controls). The follow-on CRA and Special-Purpose Programs action is what adverse-action notice operations lead does next: implement the option, assign an owner, and log the missing fact.