Assess whether the exam response should concede a finding (fa804e)

SITUATION A SPCP that originated almost no loans to the intended class put adverse-action notice principal-reason sample in front of HMDA data-quality manager in a small-business desk using a new vendor score. This Fair Lending / Examination and Notices decision is the exam response should from adverse-action notice principal-reason sample, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

DECISION HMDA data-quality manager 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 adverse-action notice principal-reason sample after a SPCP that originated almost no loans to the intended class.

HYPOTHESES TO TEST 1. A SPCP that originated almost no loans to the intended class is noise around an already-controlled Examination and Notices process in a small-business desk using a new vendor score, given adverse-action notice principal-reason sample. 2. A SPCP that originated almost no loans to the intended class is the event in adverse-action notice principal-reason sample that forces Remove access or reverse the item for HMDA data-quality manager under Fair Lending. 3. Adverse-action notice principal-reason sample shows a one-file miss after a SPCP that originated almost no loans to the intended class, not a Examination and Notices program failure. 4. Adverse-action notice principal-reason sample cannot decide the exam response should yet after a SPCP that originated almost no loans to the intended class; hold is the only Fair Lending close a small-business desk using a new vendor score can defend.

ANALYSIS REQUIRED 1. Flag any disparate-impact table HMDA data-quality manager cannot explain from adverse-action notice principal-reason sample. 2. Test a documented exception versus a pattern a small-business desk using a new vendor score must defend. 3. Match the adverse-action language to the facts in adverse-action notice principal-reason sample. 4. For this Fair Lending Examination and Notices file, read adverse-action notice principal-reason sample against a SPCP that originated almost no loans to the intended class and write the one fact that would move the exam response should 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 / Examination and Notices packet (adverse-action notice principal-reason sample after a SPCP that originated almost no loans to the intended class). The follow-on Examination and Notices action is what HMDA data-quality manager does next: implement the option, assign an owner, and log the missing fact.