Community-development lender must resolve whether comparative files show

Situation

The desk packet is small-business decline comparative file set after a community complaint about appraisal gaps. Community-development lender in a bank with thin HMDA LAR quality has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending Pricing and Credit Limits file.

Decision

Community-development lender in a bank with thin HMDA LAR quality must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using small-business decline comparative file set after a community complaint about appraisal gaps.

Hypotheses to test

• Authorize Remove access or reverse the item now; small-business decline comparative file set already has the discriminator after a community complaint about appraisal gaps.
• Keep Temporary compensating control in force until small-business decline comparative file set is completed after a community complaint about appraisal gaps for community-development lender.
• Treat small-business decline comparative file set as Approve a documented exception because both readings appear after a community complaint about appraisal gaps.
• Refuse a Fair Lending close: community-development lender does not have the page comparative files show second-review turns on in small-business decline comparative file set.

Analysis required

• Flag any disparate-impact table community-development lender cannot explain from small-business decline comparative file set.
• Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend.
• Match the adverse-action language to the facts in small-business decline comparative file set.
• For this Fair Lending Pricing and Credit Limits file, read small-business decline comparative file set against a community complaint about appraisal gaps and write the one fact that would move comparative files show second-review for community-development lender.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Pricing and Credit Limits packet (small-business decline comparative file set after a community complaint about appraisal gaps). Lead with the Fair Lending option small-business decline comparative file set can support after a community complaint about appraisal gaps, then the two facts that force it, then the Monday action for community-development lender in a bank with thin HMDA LAR quality.