Assess whether the exam response should concede a finding after a CRA PE that

SITUATION A CRA PE that called the assessment area too narrow put model-reason-code mapping that does not match notices in front of adverse-action notice operations lead in a credit union rolling out a special-purpose credit program. This Fair Lending / Pricing and Credit Limits decision is the exam response should from model-reason-code mapping that does not match notices, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

DECISION Adverse-action notice operations lead in a credit union rolling out a special-purpose credit program must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using model-reason-code mapping that does not match notices after a CRA PE that called the assessment area too narrow.

HYPOTHESES TO TEST 1. Model-reason-code mapping that does not match notices reads as Remove access or reverse the item once a CRA PE that called the assessment area too narrow is lined up to the same Fair Lending population. 2. Model-reason-code mapping that does not match notices is closer to Temporary compensating control after a CRA PE that called the assessment area too narrow; Remove access or reverse the item would over-claim this Pricing and Credit Limits extract. 3. Approve a documented exception is still live in model-reason-code mapping that does not match notices for adverse-action notice operations lead in a credit union rolling out a special-purpose credit program. 4. Model-reason-code mapping that does not match notices is missing the fact adverse-action notice operations lead needs after a CRA PE that called the assessment area too narrow; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against the exam response should. 2. Compare model-reason-code mapping that does not match notices 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 adverse-action notice operations lead cannot explain from model-reason-code mapping that does not match notices. 4. For this Fair Lending Pricing and Credit Limits file, read model-reason-code mapping that does not match notices against a CRA PE that called the assessment area too narrow and write the one fact that would move the exam response should for adverse-action notice operations lead.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Pricing and Credit Limits packet (model-reason-code mapping that does not match notices after a CRA PE that called the assessment area too narrow). Lead with the Fair Lending option model-reason-code mapping that does not match notices can support after a CRA PE that called the assessment area too narrow, then the two facts that force it, then the Monday action for adverse-action notice operations lead in a credit union rolling out a special-purpose credit program.