Assess whether the exam response should concede a finding (de8ac6)

SITUATION The CRA and Special-Purpose Programs working file is appraisal-gap outcomes in majority-minority tracts after a branch that stopped taking applications in one ZIP. Adverse-action notice operations lead in a small-business desk using a new vendor score must name Remove access or reverse the item or Temporary compensating control for this Fair Lending file. Adverse-action notice operations lead in a small-business desk using a new vendor score has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending CRA and Special-Purpose Programs file.

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 appraisal-gap outcomes in majority-minority tracts after a branch that stopped taking applications in one ZIP.

HYPOTHESES TO TEST 1. The population in appraisal-gap outcomes in majority-minority tracts is the one a branch that stopped taking applications in one ZIP named, so Remove access or reverse the item follows for this CRA and Special-Purpose Programs file. 2. The population in appraisal-gap outcomes in majority-minority tracts is adjacent only to a branch that stopped taking applications in one ZIP; Temporary compensating control is the honest Fair Lending call. 3. A small-business desk using a new vendor score already contained a branch that stopped taking applications in one ZIP before appraisal-gap outcomes in majority-minority tracts arrived; no new CRA and Special-Purpose Programs path. 4. Provenance on appraisal-gap outcomes in majority-minority tracts after a branch that stopped taking applications in one ZIP is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

ANALYSIS REQUIRED 1. Compare appraisal-gap outcomes in majority-minority tracts to similarly situated files, second-review notes, and reason codes after a branch that stopped taking applications in one ZIP. 2. Flag any disparate-impact table adverse-action notice operations lead cannot explain from appraisal-gap outcomes in majority-minority tracts. 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 appraisal-gap outcomes in majority-minority tracts against a branch that stopped taking applications in one ZIP and write the one fact that would move the exam response should 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 (appraisal-gap outcomes in majority-minority tracts after a branch that stopped taking applications in one ZIP). If appraisal-gap outcomes in majority-minority tracts cannot force a Fair Lending label under CRA and Special-Purpose Programs, stop. If appraisal-gap outcomes in majority-minority tracts after a branch that stopped taking applications in one ZIP cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending CRA and Special-Purpose Programs close, adverse-action notice operations lead must do not infer a control or scheme beyond the transaction and entitlement evidence.