Assess whether the exam response should concede a finding (cf576b)

SITUATION In a manufactured-housing lender with dealer-originated files, HMDA LAR validity and quality edits is the evidence after a CRA PE that called the assessment area too narrow. Exam-response coordinator has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending CRA and Special-Purpose Programs close using HMDA LAR validity and quality edits.

DECISION Exam-response coordinator in a manufactured-housing lender with dealer-originated files must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using HMDA LAR validity and quality edits after a CRA PE that called the assessment area too narrow.

HYPOTHESES TO TEST 1. The population in HMDA LAR validity and quality edits is the one a CRA PE that called the assessment area too narrow named, so Remove access or reverse the item follows for this CRA and Special-Purpose Programs file. 2. The population in HMDA LAR validity and quality edits is adjacent only to a CRA PE that called the assessment area too narrow; Temporary compensating control is the honest Fair Lending call. 3. A manufactured-housing lender with dealer-originated files already contained a CRA PE that called the assessment area too narrow before HMDA LAR validity and quality edits arrived; no new CRA and Special-Purpose Programs path. 4. Provenance on HMDA LAR validity and quality edits after a CRA PE that called the assessment area too narrow is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against the exam response should. 2. Compare HMDA LAR validity and quality edits to similarly situated files, second-review notes, and reason codes after a CRA PE that called the assessment area too narrow. 3. Flag any disparate-impact table exam-response coordinator cannot explain from HMDA LAR validity and quality edits. 4. For this Fair Lending CRA and Special-Purpose Programs file, read HMDA LAR validity and quality edits against a CRA PE that called the assessment area too narrow 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 / CRA and Special-Purpose Programs packet (HMDA LAR validity and quality edits after a CRA PE that called the assessment area too narrow). The follow-on CRA and Special-Purpose Programs action is what exam-response coordinator does next: implement the option, assign an owner, and log the missing fact.