Assess whether the exam response should concede a finding (263d9a)

SITUATION After a branch that stopped taking applications in one ZIP, credit-card limit assignment disparity table is what fair-lending officer can touch in a manufactured-housing lender with dealer-originated files. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this Redlining and HMDA Data file.

DECISION Fair-lending officer in a manufactured-housing lender with dealer-originated files must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using credit-card limit assignment disparity table after a branch that stopped taking applications in one ZIP.

HYPOTHESES TO TEST 1. Fair-lending officer can defend Remove access or reverse the item from credit-card limit assignment disparity table after a branch that stopped taking applications in one ZIP in a Fair Lending challenge. 2. Fair-lending officer cannot defend Remove access or reverse the item from credit-card limit assignment disparity table; Temporary compensating control is what the extract actually supports after a branch that stopped taking applications in one ZIP. 3. A branch that stopped taking applications in one ZIP never reached the population in credit-card limit assignment disparity table — reopen intake, do not close the exam response should. 4. Two facts in credit-card limit assignment disparity table after a branch that stopped taking applications in one ZIP conflict for fair-lending officer; hold this Redlining and HMDA Data file.

ANALYSIS REQUIRED 1. Flag any disparate-impact table fair-lending officer cannot explain from credit-card limit assignment disparity table. 2. Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend. 3. Match the adverse-action language to the facts in credit-card limit assignment disparity table. 4. For this Fair Lending Redlining and HMDA Data file, read credit-card limit assignment disparity table against a branch that stopped taking applications in one ZIP and write the one fact that would move the exam response should for fair-lending officer.

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 (credit-card limit assignment disparity table after a branch that stopped taking applications in one ZIP). If credit-card limit assignment disparity table cannot force a Fair Lending label under Redlining and HMDA Data, stop. If credit-card limit assignment disparity table after a branch that stopped taking applications in one ZIP cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending Redlining and HMDA Data close, fair-lending officer must do not infer a control or scheme beyond the transaction and entitlement evidence.