Whether the exam response should concede a finding from geographic

SITUATION Community-development lender is responsible for the exam response should in a bank, using thin HMDA LAR quality with geographic application and origination heat map as the only working extract. A branch that stopped taking applications in one ZIP is what reset the timeline for this Fair Lending Pricing and Credit Limits file.

DECISION Community-development lender 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 geographic application and origination heat map after a branch that stopped taking applications in one ZIP.

HYPOTHESES TO TEST 1. Community-development lender can defend Remove access or reverse the item from geographic application and origination heat map after a branch that stopped taking applications in one ZIP in a Fair Lending challenge. 2. Community-development lender cannot defend Remove access or reverse the item from geographic application and origination heat map; Temporary compensating control is what the extract actually supports after a branch that stopped taking applications in one ZIP. 3. A branch that stopped taking applications in one ZIP never reached the population in geographic application and origination heat map — reopen intake, do not close the exam response should. 4. Two facts in geographic application and origination heat map after a branch that stopped taking applications in one ZIP conflict for community-development lender; hold this Pricing and Credit Limits file.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend. 2. Match the adverse-action language to the facts in geographic application and origination heat map. 3. Check HMDA coding and underwriting policy against the exam response should. 4. For this Fair Lending Pricing and Credit Limits file, read geographic application and origination heat map against a branch that stopped taking applications in one ZIP 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 / Pricing and Credit Limits packet (geographic application and origination heat map after a branch that stopped taking applications in one ZIP). The follow-on Pricing and Credit Limits action is what community-development lender does next: implement the option, assign an owner, and log the missing fact.

COMMAND RETURNS - Bottom-line Fair Lending option on the exam response should, then the evidence in geographic application and origination heat map, then the action for community-development lender - Hypothesis scorecard against geographic application and origination heat map: supported / rejected / untestable - Missing page in geographic application and origination heat map after a branch that stopped taking applications in one ZIP, if any - Regulatory or exam hook Pricing and Credit Limits would cite