Assess whether the exam response should concede a finding (48bcf2)

SITUATION A bank with thin HMDA LAR quality has manufactured-housing dealer overlay notes in hand following an exception rate twice as high for one group after credit controls. CRA strategist must determine whether the exam response should concede a finding for this Fair Lending Examination and Notices file.

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 manufactured-housing dealer overlay notes after an exception rate twice as high for one group after credit controls. The question on that file is whether the exam response should concede a finding.

HYPOTHESES TO TEST 1. The population in manufactured-housing dealer overlay notes is the one an exception rate twice as high for one group after credit controls named, so Remove access or reverse the item follows for this Examination and Notices file. 2. The population in manufactured-housing dealer overlay notes is adjacent only to an exception rate twice as high for one group after credit controls; Temporary compensating control is the honest Fair Lending call. 3. A bank with thin HMDA LAR quality already contained an exception rate twice as high for one group after credit controls before manufactured-housing dealer overlay notes arrived; no new Examination and Notices path. 4. Provenance on manufactured-housing dealer overlay notes after an exception rate twice as high for one group after credit controls 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 manufactured-housing dealer overlay notes to similarly situated files, second-review notes, and reason codes after an exception rate twice as high for one group after credit controls. 3. Flag any disparate-impact table CRA strategist cannot explain from manufactured-housing dealer overlay notes. 4. For this Fair Lending Examination and Notices file, read manufactured-housing dealer overlay notes against an exception rate twice as high for one group after credit controls 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 (manufactured-housing dealer overlay notes after an exception rate twice as high for one group after credit controls). Lead with the Fair Lending option manufactured-housing dealer overlay notes can support after an exception rate twice as high for one group after credit controls, then the two facts that force it, then the Monday action for CRA strategist in a bank with thin HMDA LAR quality.