Assess whether a redlining pattern exists after controls (ef74cf)

Situation

After a SPCP that originated almost no loans to the intended class, SPCP written plan versus actual originations is what HMDA data-quality manager can touch in a credit union rolling out a special-purpose credit program. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this CRA and Special-Purpose Programs file.

Decision

HMDA data-quality manager in a credit union rolling out a special-purpose credit program 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 SPCP that originated almost no loans to the intended class.

Hypotheses to test

• Authorize Remove access or reverse the item now; SPCP written plan versus actual originations already has the discriminator after a SPCP that originated almost no loans to the intended class.
• Keep Temporary compensating control in force until SPCP written plan versus actual originations is completed after a SPCP that originated almost no loans to the intended class for HMDA data-quality manager.
• Treat SPCP written plan versus actual originations as Approve a documented exception because both readings appear after a SPCP that originated almost no loans to the intended class.
• Refuse a Fair Lending close: HMDA data-quality manager does not have the page a redlining pattern exists turns on in SPCP written plan versus actual originations.

Analysis required

• Flag any disparate-impact table HMDA data-quality manager cannot explain from SPCP written plan versus actual originations.
• Test a documented exception versus a pattern a credit union rolling out a special-purpose credit program must defend.
• Match the adverse-action language to the facts in SPCP written plan versus actual originations.
• For this Fair Lending CRA and Special-Purpose Programs file, read SPCP written plan versus actual originations against a SPCP that originated almost no loans to the intended class and write the one fact that would move a redlining pattern exists for HMDA data-quality manager.

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 SPCP that originated almost no loans to the intended class). Lead with the Fair Lending option SPCP written plan versus actual originations can support after a SPCP that originated almost no loans to the intended class, then the two facts that force it, then the Monday action for HMDA data-quality manager in a credit union rolling out a special-purpose credit program.