Assess whether the exam response should concede a finding (bfb396)

SITUATION The working file is geographic application and origination heat map after a CRA PE that called the assessment area too narrow. Exam-response coordinator in a bank with thin HMDA LAR quality has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending Redlining and HMDA Data file.

DECISION Exam-response coordinator in a bank with thin HMDA LAR quality must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using geographic application and origination heat map after a CRA PE that called the assessment area too narrow.

HYPOTHESES TO TEST 1. Geographic application and origination heat map reads as Remove access or reverse the item once a CRA PE that called the assessment area too narrow is lined up to the same Fair Lending population. 2. Geographic application and origination heat map is closer to Temporary compensating control after a CRA PE that called the assessment area too narrow; Remove access or reverse the item would over-claim this Redlining and HMDA Data extract. 3. Approve a documented exception is still live in geographic application and origination heat map for exam-response coordinator in a bank with thin HMDA LAR quality. 4. Geographic application and origination heat map is missing the fact exam-response coordinator needs after a CRA PE that called the assessment area too narrow; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend. 2. Match the adverse-action language to the facts in geographic application and origination heat map. 3. Check HMDA coding and underwriting policy against the exam response should. 4. For this Fair Lending Redlining and HMDA Data file, read geographic application and origination heat map against a CRA PE that called the assessment area too narrow and write the one fact that would move the exam response should for exam-response coordinator.

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 (geographic application and origination heat map after a CRA PE that called the assessment area too narrow). The follow-on Redlining and HMDA Data action is what exam-response coordinator 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 geographic application and origination heat map, then the action for exam-response coordinator - Hypothesis scorecard against geographic application and origination heat map: supported / rejected / untestable - What changes the exam response should if a CRA PE that called the assessment area too narrow 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