Assess whether notices match the actual decisioning reasons (849a1d)

SITUATION A lender expanding into majority-minority census tracts cannot treat a branch that stopped taking applications in one ZIP as incidental context on small-business decline comparative file set. HMDA data-quality manager must close notices match the actual from that extract under Fair Lending / Pricing and Credit Limits.

DECISION HMDA data-quality manager in a lender expanding into majority-minority census tracts 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. HMDA data-quality manager can defend Remove access or reverse the item from small-business decline comparative file set after a branch that stopped taking applications in one ZIP in a Fair Lending challenge. 2. HMDA data-quality manager cannot defend Remove access or reverse the item from small-business decline comparative file set; Temporary compensating control is what the extract actually supports after a branch that stopped taking applications in one ZIP. 3. A branch that stopped taking applications in one ZIP never reached the population in small-business decline comparative file set — reopen intake, do not close notices match the actual. 4. Two facts in small-business decline comparative file set after a branch that stopped taking applications in one ZIP conflict for HMDA data-quality manager; hold this Pricing and Credit Limits file.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in small-business decline comparative file set. 2. Check HMDA coding and underwriting policy against notices match the actual. 3. Compare small-business decline comparative file set to similarly situated files, second-review notes, and reason codes after a branch that stopped taking applications in one ZIP. 4. For this Fair Lending Pricing and Credit Limits 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 notices match the actual for HMDA data-quality manager.

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 (small-business decline comparative file set after a branch that stopped taking applications in one ZIP). The follow-on Pricing and Credit Limits action is what HMDA data-quality manager does next: implement the option, assign an owner, and log the missing fact.

COMMAND RETURNS - Bottom-line Fair Lending option on notices match the actual, then the evidence in small-business decline comparative file set, then the action for HMDA data-quality manager - Hypothesis scorecard against small-business decline comparative file set: supported / rejected / untestable - Named option among Remove access or reverse the item, Temporary compensating control, Approve a documented exception and the fact that kills the others - Owner and next date for HMDA data-quality manager in a lender expanding into majority-minority census tracts