Assess whether the exam response should concede a finding (76d5a7)

SITUATION Exam-response coordinator in a mortgage company after a pricing-regression spike has one working extract — geographic application and origination heat map — after a vendor score change with no disparate-impact test. If geographic application and origination heat map cannot support the exam response should, the only defensible Fair Lending output is hold.

DECISION Exam-response coordinator 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 geographic application and origination heat map after a vendor score change with no disparate-impact test.

HYPOTHESES TO TEST 1. Geographic application and origination heat map reads as Remove access or reverse the item once a vendor score change with no disparate-impact test is lined up to the same Fair Lending population. 2. Geographic application and origination heat map is closer to Temporary compensating control after a vendor score change with no disparate-impact test; Remove access or reverse the item would over-claim this Examination and Notices extract. 3. Approve a documented exception is still live in geographic application and origination heat map for exam-response coordinator in a mortgage company after a pricing-regression spike. 4. Geographic application and origination heat map is missing the fact exam-response coordinator needs after a vendor score change with no disparate-impact test; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against the exam response should. 2. Compare geographic application and origination heat map to similarly situated files, second-review notes, and reason codes after a vendor score change with no disparate-impact test. 3. Flag any disparate-impact table exam-response coordinator cannot explain from geographic application and origination heat map. 4. For this Fair Lending Examination and Notices file, read geographic application and origination heat map against a vendor score change with no disparate-impact test and write the one fact that would move the exam response should for exam-response coordinator.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Examination and Notices packet (geographic application and origination heat map after a vendor score change with no disparate-impact test). The follow-on Examination and Notices action is what exam-response coordinator 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 exam-response coordinator - Hypothesis scorecard against geographic application and origination heat map: supported / rejected / untestable - What changes the exam response should if a vendor score change with no disparate-impact test is later withdrawn - Named option among Remove access or reverse the item, Temporary compensating control, Approve a documented exception and the fact that kills the others