Assess whether the exam response should concede a finding (b493b5)

SITUATION Mortgage pricing residual by prohibited-basis group arrived with a SPCP that originated almost no loans to the intended class for exam-response coordinator. That is a Fair Lending Redlining and HMDA Data decision on the exam response should in a bank with thin HMDA LAR quality.

DECISION Exam-response coordinator 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 mortgage pricing residual by prohibited-basis group after a SPCP that originated almost no loans to the intended class.

HYPOTHESES TO TEST 1. Exam-response coordinator can defend Remove access or reverse the item from mortgage pricing residual by prohibited-basis group after a SPCP that originated almost no loans to the intended class in a Fair Lending challenge. 2. Exam-response coordinator cannot defend Remove access or reverse the item from mortgage pricing residual by prohibited-basis group; Temporary compensating control is what the extract actually supports after a SPCP that originated almost no loans to the intended class. 3. A SPCP that originated almost no loans to the intended class never reached the population in mortgage pricing residual by prohibited-basis group — reopen intake, do not close the exam response should. 4. Two facts in mortgage pricing residual by prohibited-basis group after a SPCP that originated almost no loans to the intended class conflict for exam-response coordinator; hold this Redlining and HMDA Data file.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against the exam response should. 2. Compare mortgage pricing residual by prohibited-basis group to similarly situated files, second-review notes, and reason codes after a SPCP that originated almost no loans to the intended class. 3. Flag any disparate-impact table exam-response coordinator cannot explain from mortgage pricing residual by prohibited-basis group. 4. For this Fair Lending Redlining and HMDA Data file, read mortgage pricing residual by prohibited-basis group against a SPCP that originated almost no loans to the intended class and write the one fact that would move the exam response should for exam-response coordinator.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Redlining and HMDA Data packet (mortgage pricing residual by prohibited-basis group after a SPCP that originated almost no loans to the intended class). The follow-on Redlining and HMDA Data action is what exam-response coordinator does next: implement the option, assign an owner, and log the missing fact.