Assess whether the exam response should concede a finding (c94e57)

SITUATION After a branch that stopped taking applications in one ZIP, small-business decline comparative file set is what exam-response coordinator can touch in a manufactured-housing lender with dealer-originated files. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this CRA and Special-Purpose Programs file.

DECISION Exam-response coordinator in a manufactured-housing lender with dealer-originated files must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using small-business decline comparative file set after a branch that stopped taking applications in one ZIP.

HYPOTHESES TO TEST 1. A branch that stopped taking applications in one ZIP is noise around an already-controlled CRA and Special-Purpose Programs process in a manufactured-housing lender with dealer-originated files, given small-business decline comparative file set. 2. A branch that stopped taking applications in one ZIP is the event in small-business decline comparative file set that forces Remove access or reverse the item for exam-response coordinator under Fair Lending. 3. Small-business decline comparative file set shows a one-file miss after a branch that stopped taking applications in one ZIP, not a CRA and Special-Purpose Programs program failure. 4. Small-business decline comparative file set cannot decide the exam response should yet after a branch that stopped taking applications in one ZIP; hold is the only Fair Lending close a manufactured-housing lender with dealer-originated files can defend.

ANALYSIS REQUIRED 1. Flag any disparate-impact table exam-response coordinator cannot explain from small-business decline comparative file set. 2. Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend. 3. Match the adverse-action language to the facts in small-business decline comparative file set. 4. For this Fair Lending CRA and Special-Purpose Programs file, read small-business decline comparative file set against a branch that stopped taking applications in one ZIP 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 / CRA and Special-Purpose Programs packet (small-business decline comparative file set after a branch that stopped taking applications in one ZIP). The follow-on CRA and Special-Purpose Programs action is what exam-response coordinator does next: implement the option, assign an owner, and log the missing fact.