Assess whether the exam response should concede a finding (990fd2)

SITUATION In a bank with thin HMDA LAR quality, CRA assessment-area versus lending footprint is the evidence after a HMDA resubmission that still fails quality edits. Fair-lending officer has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending CRA and Special-Purpose Programs close using CRA assessment-area versus lending footprint.

DECISION Fair-lending officer in a bank with thin HMDA LAR quality 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 HMDA resubmission that still fails quality edits.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; CRA assessment-area versus lending footprint already has the discriminator after a HMDA resubmission that still fails quality edits. 2. Keep Temporary compensating control in force until CRA assessment-area versus lending footprint is completed after a HMDA resubmission that still fails quality edits for fair-lending officer. 3. Treat CRA assessment-area versus lending footprint as Approve a documented exception because both readings appear after a HMDA resubmission that still fails quality edits. 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. Match the adverse-action language to the facts in CRA assessment-area versus lending footprint. 2. Check HMDA coding and underwriting policy against the exam response should. 3. Compare CRA assessment-area versus lending footprint to similarly situated files, second-review notes, and reason codes after a HMDA resubmission that still fails quality edits. 4. For this Fair Lending CRA and Special-Purpose Programs file, read CRA assessment-area versus lending footprint against a HMDA resubmission that still fails quality edits 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 / CRA and Special-Purpose Programs packet (CRA assessment-area versus lending footprint after a HMDA resubmission that still fails quality edits). Lead with the Fair Lending option CRA assessment-area versus lending footprint can support after a HMDA resubmission that still fails quality edits, then the two facts that force it, then the Monday action for fair-lending officer in a bank with thin HMDA LAR quality.

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 - Owner and next date for fair-lending officer in a bank with thin HMDA LAR quality - What changes the exam response should if a HMDA resubmission that still fails quality edits is later withdrawn