Assess whether the exam response should concede a finding (097e78)

SITUATION In a mortgage company after a pricing-regression spike, a marketing mailer that skipped majority-minority tracts put credit-card limit assignment disparity table in play. Community-development lender should decide whether the exam response should concede a finding without filling gaps credit-card limit assignment disparity table does not contain.

DECISION Community-development lender 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 credit-card limit assignment disparity table after a marketing mailer that skipped majority-minority tracts.

HYPOTHESES TO TEST 1. Credit-card limit assignment disparity table 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. Credit-card limit assignment disparity table 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 credit-card limit assignment disparity table for community-development lender in a mortgage company after a pricing-regression spike. 4. Credit-card limit assignment disparity table is missing the fact community-development lender needs after a marketing mailer that skipped majority-minority tracts; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern a mortgage company after a pricing-regression spike must defend. 2. Match the adverse-action language to the facts in credit-card limit assignment disparity table. 3. Check HMDA coding and underwriting policy against the exam response should. 4. For this Fair Lending Redlining and HMDA Data file, read credit-card limit assignment disparity table against a marketing mailer that skipped majority-minority tracts and write the one fact that would move the exam response should for community-development lender.

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 (credit-card limit assignment disparity table after a marketing mailer that skipped majority-minority tracts). Lead with the Fair Lending option credit-card limit assignment disparity table can support after a marketing mailer that skipped majority-minority tracts, then the two facts that force it, then the Monday action for community-development lender in a mortgage company after a pricing-regression spike.