Assess whether the exam response should concede a finding (6f0647)

SITUATION Appraisal-gap outcomes in majority-minority tracts arrived with a HMDA resubmission that still fails quality edits for HMDA data-quality manager. That is a Fair Lending Examination and Notices decision on the exam response should in a small-business desk using a new vendor score.

DECISION HMDA data-quality manager in a small-business desk using a new vendor score 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 HMDA resubmission that still fails quality edits.

HYPOTHESES TO TEST 1. A HMDA resubmission that still fails quality edits is noise around an already-controlled Examination and Notices process in a small-business desk using a new vendor score, given appraisal-gap outcomes in majority-minority tracts. 2. A HMDA resubmission that still fails quality edits is the event in appraisal-gap outcomes in majority-minority tracts that forces Remove access or reverse the item for HMDA data-quality manager under Fair Lending. 3. Appraisal-gap outcomes in majority-minority tracts shows a one-file miss after a HMDA resubmission that still fails quality edits, not a Examination and Notices program failure. 4. Appraisal-gap outcomes in majority-minority tracts cannot decide the exam response should yet after a HMDA resubmission that still fails quality edits; hold is the only Fair Lending close a small-business desk using a new vendor score can defend.

ANALYSIS REQUIRED 1. Flag any disparate-impact table HMDA data-quality manager cannot explain from appraisal-gap outcomes in majority-minority tracts. 2. Test a documented exception versus a pattern a small-business desk using a new vendor score must defend. 3. Match the adverse-action language to the facts in appraisal-gap outcomes in majority-minority tracts. 4. For this Fair Lending Examination and Notices file, read appraisal-gap outcomes in majority-minority tracts against a HMDA resubmission that still fails quality edits 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 / Examination and Notices packet (appraisal-gap outcomes in majority-minority tracts after a HMDA resubmission that still fails quality edits). The follow-on Examination and Notices 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 - What changes the exam response should if a HMDA resubmission that still fails quality edits is later withdrawn - Named option among Remove access or reverse the item, Temporary compensating control, Approve a documented exception and the fact that kills the others