Assess whether the exam response should concede a finding (937b21)

SITUATION After a marketing mailer that skipped majority-minority tracts, HMDA LAR validity and quality edits is what second-review underwriter can touch in a lender expanding into majority-minority census tracts. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this CRA and Special-Purpose Programs file.

DECISION Second-review underwriter in a lender expanding into majority-minority census tracts 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 marketing mailer that skipped majority-minority tracts.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; HMDA LAR validity and quality edits already has the discriminator after a marketing mailer that skipped majority-minority tracts. 2. Keep Temporary compensating control in force until HMDA LAR validity and quality edits is completed after a marketing mailer that skipped majority-minority tracts for second-review underwriter. 3. Treat HMDA LAR validity and quality edits as Approve a documented exception because both readings appear after a marketing mailer that skipped majority-minority tracts. 4. Refuse a Fair Lending close: second-review underwriter does not have the decision the exam response should turns on in HMDA LAR validity and quality edits.

ANALYSIS REQUIRED 1. Flag any disparate-impact table second-review underwriter cannot explain from HMDA LAR validity and quality edits. 2. Test a documented exception versus a pattern a lender expanding into majority-minority census tracts must defend. 3. Match the adverse-action language to the facts in 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 marketing mailer that skipped majority-minority tracts and write the one fact that would move the exam response should for second-review underwriter.

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 marketing mailer that skipped majority-minority tracts). The follow-on CRA and Special-Purpose Programs action is what second-review underwriter 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 HMDA LAR validity and quality edits, then the action for second-review underwriter - Hypothesis scorecard against HMDA LAR validity and quality edits: supported / rejected / untestable - What changes the exam response should if a marketing mailer that skipped majority-minority tracts 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