Assess whether the exam response should concede a finding (359d06)

SITUATION HMDA data-quality manager received appraisal-gap outcomes in majority-minority tracts after a community complaint about appraisal gaps in a credit-card issuer changing line-assignment logic. Remove access or reverse the item or Temporary compensating control must follow from that extract if the file can settle whether the exam response should concede a finding.

DECISION HMDA data-quality manager in a credit-card issuer changing line-assignment logic 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 community complaint about appraisal gaps. The question on that file is whether the exam response should concede a finding.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; appraisal-gap outcomes in majority-minority tracts already has the discriminator after a community complaint about appraisal gaps. 2. Keep Temporary compensating control in force until appraisal-gap outcomes in majority-minority tracts is completed after a community complaint about appraisal gaps for HMDA data-quality manager. 3. Treat appraisal-gap outcomes in majority-minority tracts as Approve a documented exception because both readings appear after a community complaint about appraisal gaps. 4. Refuse a Fair Lending close: HMDA data-quality manager does not have the decision the exam response should turns on in appraisal-gap outcomes in majority-minority tracts.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in appraisal-gap outcomes in majority-minority tracts. 2. Check HMDA coding and underwriting policy against the exam response should. 3. Compare appraisal-gap outcomes in majority-minority tracts to similarly situated files, second-review notes, and reason codes after a community complaint about appraisal gaps. 4. For this Fair Lending Redlining and HMDA Data file, read appraisal-gap outcomes in majority-minority tracts against a community complaint about appraisal gaps 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 / Redlining and HMDA Data packet (appraisal-gap outcomes in majority-minority tracts after a community complaint about appraisal gaps). Lead with the Fair Lending option appraisal-gap outcomes in majority-minority tracts can support after a community complaint about appraisal gaps, then the two facts that force it, then the Monday action for HMDA data-quality manager in a credit-card issuer changing line-assignment logic.