Assess whether the exam response should concede a finding (748890)

SITUATION A notice that cites 'other' as the principal reason 40% of the time put mortgage pricing residual by prohibited-basis group in front of CRA strategist in a mortgage company after a pricing-regression spike. This Fair Lending / CRA and Special-Purpose Programs decision is the exam response should from mortgage pricing residual by prohibited-basis group, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

DECISION CRA strategist in a mortgage company after a pricing-regression spike 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 notice that cites 'other' as the principal reason 40% of the time.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; mortgage pricing residual by prohibited-basis group already has the discriminator after a notice that cites 'other' as the principal reason 40% of the time. 2. Keep Temporary compensating control in force until mortgage pricing residual by prohibited-basis group is completed after a notice that cites 'other' as the principal reason 40% of the time for CRA strategist. 3. Treat mortgage pricing residual by prohibited-basis group as Approve a documented exception because both readings appear after a notice that cites 'other' as the principal reason 40% of the time. 4. Refuse a Fair Lending close: CRA strategist does not have the decision the exam response should turns on in mortgage pricing residual by prohibited-basis group.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in mortgage pricing residual by prohibited-basis group. 2. Check HMDA coding and underwriting policy against the exam response should. 3. Compare mortgage pricing residual by prohibited-basis group to similarly situated files, second-review notes, and reason codes after a notice that cites 'other' as the principal reason 40% of the time. 4. For this Fair Lending CRA and Special-Purpose Programs file, read mortgage pricing residual by prohibited-basis group 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 / CRA and Special-Purpose Programs packet (mortgage pricing residual by prohibited-basis group after a notice that cites 'other' as the principal reason 40% of the time). Lead with the Fair Lending option mortgage pricing residual by prohibited-basis group 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 mortgage company after a pricing-regression spike.