Assess whether the exam response should concede a finding (9bce87)

SITUATION Appraisal-gap outcomes in majority-minority tracts arrived with a marketing mailer that skipped majority-minority tracts for CRA strategist. That is a Fair Lending Redlining and HMDA Data decision on the exam response should in an institution preparing for a redlining exam.

DECISION CRA strategist in an institution preparing for a redlining exam must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using appraisal-gap outcomes in majority-minority tracts after a marketing mailer that skipped majority-minority tracts.

HYPOTHESES TO TEST 1. Appraisal-gap outcomes in majority-minority tracts reads as Remove access or reverse the item once a marketing mailer that skipped majority-minority tracts is lined up to the same Fair Lending population. 2. Appraisal-gap outcomes in majority-minority tracts is closer to Temporary compensating control after a marketing mailer that skipped majority-minority tracts; Remove access or reverse the item would over-claim this Redlining and HMDA Data extract. 3. Approve a documented exception is still live in appraisal-gap outcomes in majority-minority tracts for CRA strategist in an institution preparing for a redlining exam. 4. Appraisal-gap outcomes in majority-minority tracts is missing the fact CRA strategist needs after a marketing mailer that skipped majority-minority tracts; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in appraisal-gap outcomes in majority-minority tracts. 2. Check HMDA coding and underwriting policy against the exam response should. 3. Compare appraisal-gap outcomes in majority-minority tracts to similarly situated files, second-review notes, and reason codes after a marketing mailer that skipped majority-minority tracts. 4. For this Fair Lending Redlining and HMDA Data file, read appraisal-gap outcomes in majority-minority tracts against a marketing mailer that skipped majority-minority tracts and write the one fact that would move the exam response should for CRA strategist.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Redlining and HMDA Data packet (appraisal-gap outcomes in majority-minority tracts after a marketing mailer that skipped majority-minority tracts). The follow-on Redlining and HMDA Data action is what CRA strategist does next: implement the option, assign an owner, and log the missing fact.

COMMAND RETURNS - Bottom-line Fair Lending option on the exam response should, then the evidence in appraisal-gap outcomes in majority-minority tracts, then the action for CRA strategist - Hypothesis scorecard against appraisal-gap outcomes in majority-minority tracts: supported / rejected / untestable - Owner and next date for CRA strategist in an institution preparing for a redlining exam - What changes the exam response should if a marketing mailer that skipped majority-minority tracts is later withdrawn