Assess whether the exam response should concede a finding (e66e06)

SITUATION The CRA and Special-Purpose Programs working file is adverse-action notice principal-reason sample after a vendor score change with no disparate-impact test. Community-development lender in an institution preparing for a redlining exam must name Remove access or reverse the item or Temporary compensating control for this Fair Lending file. Community-development lender in an institution preparing for a redlining exam has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending CRA and Special-Purpose Programs file.

DECISION Community-development lender in an institution preparing for a redlining exam must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using adverse-action notice principal-reason sample after a vendor score change with no disparate-impact test.

HYPOTHESES TO TEST 1. Adverse-action notice principal-reason sample reads as Remove access or reverse the item once a vendor score change with no disparate-impact test is lined up to the same Fair Lending population. 2. Adverse-action notice principal-reason sample is closer to Temporary compensating control after a vendor score change with no disparate-impact test; Remove access or reverse the item would over-claim this CRA and Special-Purpose Programs extract. 3. Approve a documented exception is still live in adverse-action notice principal-reason sample for community-development lender in an institution preparing for a redlining exam. 4. Adverse-action notice principal-reason sample is missing the fact community-development lender needs after a vendor score change with no disparate-impact test; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Compare adverse-action notice principal-reason sample to similarly situated files, second-review notes, and reason codes after a vendor score change with no disparate-impact test. 2. Flag any disparate-impact table community-development lender cannot explain from adverse-action notice principal-reason sample. 3. Test a documented exception versus a pattern an institution preparing for a redlining exam must defend. 4. For this Fair Lending CRA and Special-Purpose Programs file, read adverse-action notice principal-reason sample against a vendor score change with no disparate-impact test and write the one fact that would move the exam response should for community-development lender.

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 (adverse-action notice principal-reason sample after a vendor score change with no disparate-impact test). Lead with the Fair Lending option adverse-action notice principal-reason sample can support after a vendor score change with no disparate-impact test, then the two facts that force it, then the Monday action for community-development lender in an institution preparing for a redlining exam.