Assess whether the exam response should concede a finding (bd955a)

SITUATION A branch that stopped taking applications in one ZIP put CRA assessment-area versus lending footprint in front of adverse-action notice operations lead in a lender expanding into majority-minority census tracts. This Fair Lending / Redlining and HMDA Data decision is the exam response should from CRA assessment-area versus lending footprint, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

DECISION Adverse-action notice operations lead in a lender expanding into majority-minority census tracts 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 branch that stopped taking applications in one ZIP.

HYPOTHESES TO TEST 1. The population in CRA assessment-area versus lending footprint is the one a branch that stopped taking applications in one ZIP named, so Remove access or reverse the item follows for this Redlining and HMDA Data file. 2. The population in CRA assessment-area versus lending footprint is adjacent only to a branch that stopped taking applications in one ZIP; Temporary compensating control is the honest Fair Lending call. 3. A lender expanding into majority-minority census tracts already contained a branch that stopped taking applications in one ZIP before CRA assessment-area versus lending footprint arrived; no new Redlining and HMDA Data path. 4. Provenance on CRA assessment-area versus lending footprint 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. Flag any disparate-impact table adverse-action notice operations lead cannot explain from CRA assessment-area versus lending footprint. 2. Test a documented exception versus a pattern a lender expanding into majority-minority census tracts must defend. 3. Match the adverse-action language to the facts in CRA assessment-area versus lending footprint. 4. For this Fair Lending Redlining and HMDA Data file, read CRA assessment-area versus lending footprint 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 / Redlining and HMDA Data packet (CRA assessment-area versus lending footprint after a branch that stopped taking applications in one ZIP). If CRA assessment-area versus lending footprint cannot force a Fair Lending label under Redlining and HMDA Data, stop. If CRA assessment-area versus lending footprint 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 Redlining and HMDA Data close, adverse-action notice operations lead must do not infer a control or scheme beyond the transaction and entitlement evidence.