Assess whether the exam response should concede a finding (cd3152)

SITUATION A notice that cites 'other' as the principal reason 40% of the time put HMDA LAR validity and quality edits in front of CRA strategist in a bank with thin HMDA LAR quality. This Fair Lending / Examination and Notices decision is the exam response should from HMDA LAR validity and quality edits, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

DECISION CRA strategist 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 HMDA LAR validity and quality edits after a notice that cites 'other' as the principal reason 40% of the time.

HYPOTHESES TO TEST 1. CRA strategist can defend Remove access or reverse the item from HMDA LAR validity and quality edits after a notice that cites 'other' as the principal reason 40% of the time in a Fair Lending challenge. 2. CRA strategist cannot defend Remove access or reverse the item from HMDA LAR validity and quality edits; Temporary compensating control is what the extract actually supports after a notice that cites 'other' as the principal reason 40% of the time. 3. A notice that cites 'other' as the principal reason 40% of the time never reached the population in HMDA LAR validity and quality edits — reopen intake, do not close the exam response should. 4. Two facts in HMDA LAR validity and quality edits after a notice that cites 'other' as the principal reason 40% of the time conflict for CRA strategist; hold this Examination and Notices file.

ANALYSIS REQUIRED 1. Flag any disparate-impact table CRA strategist cannot explain from HMDA LAR validity and quality edits. 2. Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend. 3. Match the adverse-action language to the facts in HMDA LAR validity and quality edits. 4. For this Fair Lending Examination and Notices file, read HMDA LAR validity and quality edits against a notice that cites 'other' as the principal reason 40% of the time and write the one fact that would move the exam response should for CRA strategist.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Examination and Notices packet (HMDA LAR validity and quality edits after a notice that cites 'other' as the principal reason 40% of the time). Lead with the Fair Lending option HMDA LAR validity and quality edits can support after a notice that cites 'other' as the principal reason 40% of the time, then the two facts that force it, then the Monday action for CRA strategist in a bank with thin HMDA LAR quality.