Assess whether the exam response should concede a finding (4e2305)

SITUATION After an exception rate twice as high for one group after credit controls, appraisal-gap outcomes in majority-minority tracts is what HMDA data-quality manager can touch in a credit union rolling out a special-purpose credit program. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this CRA and Special-Purpose Programs file.

DECISION HMDA data-quality manager in a credit union rolling out a special-purpose credit program 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 an exception rate twice as high for one group after credit controls.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; appraisal-gap outcomes in majority-minority tracts already has the discriminator after an exception rate twice as high for one group after credit controls. 2. Keep Temporary compensating control in force until appraisal-gap outcomes in majority-minority tracts is completed after an exception rate twice as high for one group after credit controls for HMDA data-quality manager. 3. Treat appraisal-gap outcomes in majority-minority tracts as Approve a documented exception because both readings appear after an exception rate twice as high for one group after credit controls. 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. Check HMDA coding and underwriting policy against the exam response should. 2. Compare appraisal-gap outcomes in majority-minority tracts to similarly situated files, second-review notes, and reason codes after an exception rate twice as high for one group after credit controls. 3. Flag any disparate-impact table HMDA data-quality manager cannot explain from appraisal-gap outcomes in majority-minority tracts. 4. For this Fair Lending CRA and Special-Purpose Programs file, read appraisal-gap outcomes in majority-minority tracts against an exception rate twice as high for one group after credit controls 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 / CRA and Special-Purpose Programs packet (appraisal-gap outcomes in majority-minority tracts after an exception rate twice as high for one group after credit controls). Lead with the Fair Lending option appraisal-gap outcomes in majority-minority tracts can support after an exception rate twice as high for one group after credit controls, then the two facts that force it, then the Monday action for HMDA data-quality manager in a credit union rolling out a special-purpose credit program.