Assess whether the exam response should concede a finding (842376)

SITUATION The working file is underwriting exception log by branch after an exception rate twice as high for one group after credit controls. Exam-response coordinator in a bank with thin HMDA LAR quality has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending Redlining and HMDA Data file.

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 underwriting exception log by branch after an exception rate twice as high for one group after credit controls.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; underwriting exception log by branch already has the discriminator after an exception rate twice as high for one group after credit controls. 2. Keep Temporary compensating control in force until underwriting exception log by branch is completed after an exception rate twice as high for one group after credit controls for exam-response coordinator. 3. Treat underwriting exception log by branch as Approve a documented exception because both readings appear after an exception rate twice as high for one group after credit controls. 4. Refuse a Fair Lending close: exam-response coordinator does not have the decision the exam response should turns on in underwriting exception log by branch.

ANALYSIS REQUIRED 1. Flag any disparate-impact table exam-response coordinator cannot explain from underwriting exception log by branch. 2. Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend. 3. Match the adverse-action language to the facts in underwriting exception log by branch. 4. For this Fair Lending Redlining and HMDA Data file, read underwriting exception log by branch against an exception rate twice as high for one group after credit controls 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 (underwriting exception log by branch after an exception rate twice as high for one group after credit controls). Lead with the Fair Lending option underwriting exception log by branch can support after an exception rate twice as high for one group after credit controls, then the two facts that force it, then the Monday action for exam-response coordinator in a bank with thin HMDA LAR quality.

COMMAND RETURNS - Bottom-line Fair Lending option on the exam response should, then the evidence in underwriting exception log by branch, then the action for exam-response coordinator - Hypothesis scorecard against underwriting exception log by branch: supported / rejected / untestable - Redlining and HMDA Data finding in underwriting exception log by branch that a second reviewer can re-perform - Missing page in underwriting exception log by branch after an exception rate twice as high for one group after credit controls, if any