Assess whether the exam response should concede a finding after a vendor

SITUATION HMDA data-quality manager in a lender expanding into majority-minority census tracts has one working extract — appraisal-gap outcomes in majority-minority tracts — after a vendor score change with no disparate-impact test. If appraisal-gap outcomes in majority-minority tracts cannot support the exam response should, the only defensible Fair Lending output is hold.

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 appraisal-gap outcomes in majority-minority tracts after a vendor score change with no disparate-impact test.

HYPOTHESES TO TEST 1. Appraisal-gap outcomes in majority-minority tracts 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. Appraisal-gap outcomes in majority-minority tracts 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 Pricing and Credit Limits extract. 3. Approve a documented exception is still live in appraisal-gap outcomes in majority-minority tracts for HMDA data-quality manager in a lender expanding into majority-minority census tracts. 4. Appraisal-gap outcomes in majority-minority tracts is missing the fact HMDA data-quality manager needs after a vendor score change with no disparate-impact test; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern a lender expanding into majority-minority census tracts must defend. 2. Match the adverse-action language to the facts in appraisal-gap outcomes in majority-minority tracts. 3. Check HMDA coding and underwriting policy against the exam response should. 4. For this Fair Lending Pricing and Credit Limits file, read appraisal-gap outcomes in majority-minority tracts against a vendor score change with no disparate-impact test and write the one fact that would move the exam response should 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 (appraisal-gap outcomes in majority-minority tracts after a vendor score change with no disparate-impact test). 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 the exam response should, then the evidence in appraisal-gap outcomes in majority-minority tracts, then the action for HMDA data-quality manager - Hypothesis scorecard against appraisal-gap outcomes in majority-minority tracts: supported / rejected / untestable - Pricing and Credit Limits finding in appraisal-gap outcomes in majority-minority tracts that a second reviewer can re-perform - Missing page in appraisal-gap outcomes in majority-minority tracts after a vendor score change with no disparate-impact test, if any