Assess whether the exam response should concede a finding (fa8b5a)

SITUATION Manufactured-housing dealer overlay notes arrived with a marketing mailer that skipped majority-minority tracts. HMDA data-quality manager in a small-business desk using a new vendor score still has an evidence gap on whether the exam response should concede a finding.

DECISION HMDA data-quality manager in a small-business desk using a new vendor score must choose Remove access or reverse the item, Temporary compensating control, Approve a documented exception, Hold using manufactured-housing dealer overlay notes after a marketing mailer that skipped majority-minority tracts. The question on that file is whether the exam response should concede a finding.

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

ANALYSIS REQUIRED 1. Flag any disparate-impact table HMDA data-quality manager cannot explain from manufactured-housing dealer overlay notes. 2. Test a documented exception versus a pattern a small-business desk using a new vendor score must defend. 3. Match the adverse-action language to the facts in manufactured-housing dealer overlay notes. 4. For this Fair Lending Examination and Notices file, read manufactured-housing dealer overlay notes against a marketing mailer that skipped majority-minority tracts and write the one fact that would move the exam response should for HMDA data-quality manager.

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 a marketing mailer that skipped majority-minority tracts). If manufactured-housing dealer overlay notes cannot force a Fair Lending label under Examination and Notices, stop. If manufactured-housing dealer overlay notes after a marketing mailer that skipped majority-minority tracts cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending Examination and Notices close, HMDA data-quality manager must do not infer a control or scheme beyond the transaction and entitlement evidence.