Assess whether the exam response should concede a finding after a community

SITUATION The working file is CRA assessment-area versus lending footprint after a community complaint about appraisal gaps. Fair-lending officer in a mortgage company after a pricing-regression spike has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending Pricing and Credit Limits file.

DECISION Fair-lending officer in a mortgage company after a pricing-regression spike must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using CRA assessment-area versus lending footprint after a community complaint about appraisal gaps.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; CRA assessment-area versus lending footprint already has the discriminator after a community complaint about appraisal gaps. 2. Keep Temporary compensating control in force until CRA assessment-area versus lending footprint is completed after a community complaint about appraisal gaps for fair-lending officer. 3. Treat CRA assessment-area versus lending footprint as Approve a documented exception because both readings appear after a community complaint about appraisal gaps. 4. Refuse a Fair Lending close: fair-lending officer does not have the decision the exam response should turns on in CRA assessment-area versus lending footprint.

ANALYSIS REQUIRED 1. Compare CRA assessment-area versus lending footprint to similarly situated files, second-review notes, and reason codes after a community complaint about appraisal gaps. 2. Flag any disparate-impact table fair-lending officer cannot explain from CRA assessment-area versus lending footprint. 3. Test a documented exception versus a pattern a mortgage company after a pricing-regression spike must defend. 4. For this Fair Lending Pricing and Credit Limits file, read CRA assessment-area versus lending footprint against a community complaint about appraisal gaps and write the one fact that would move the exam response should for fair-lending officer.

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 (CRA assessment-area versus lending footprint after a community complaint about appraisal gaps). Lead with the Fair Lending option CRA assessment-area versus lending footprint can support after a community complaint about appraisal gaps, then the two facts that force it, then the Monday action for fair-lending officer in a mortgage company after a pricing-regression spike.

COMMAND RETURNS - Bottom-line Fair Lending option on the exam response should, then the evidence in CRA assessment-area versus lending footprint, then the action for fair-lending officer - Hypothesis scorecard against CRA assessment-area versus lending footprint: supported / rejected / untestable - Named option among Remove access or reverse the item, Temporary compensating control, Approve a documented exception and the fact that kills the others - Owner and next date for fair-lending officer in a mortgage company after a pricing-regression spike