Assess whether the exam response should concede a finding (86d6e4)

SITUATION In a credit union rolling out a special-purpose credit program, a notice that cites 'other' as the principal reason 40% of the time put geographic application and origination heat map in play. HMDA data-quality manager should decide whether the exam response should concede a finding without filling gaps geographic application and origination heat map does not contain.

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 geographic application and origination heat map after a notice that cites 'other' as the principal reason 40% of the time.

HYPOTHESES TO TEST 1. The population in geographic application and origination heat map is the one a notice that cites 'other' as the principal reason 40% of the time named, so Remove access or reverse the item follows for this CRA and Special-Purpose Programs file. 2. The population in geographic application and origination heat map is adjacent only to a notice that cites 'other' as the principal reason 40% of the time; Temporary compensating control is the honest Fair Lending call. 3. A credit union rolling out a special-purpose credit program already contained a notice that cites 'other' as the principal reason 40% of the time before geographic application and origination heat map arrived; no new CRA and Special-Purpose Programs path. 4. Provenance on geographic application and origination heat map after a notice that cites 'other' as the principal reason 40% of the time is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

ANALYSIS REQUIRED 1. Compare geographic application and origination heat map to similarly situated files, second-review notes, and reason codes after a notice that cites 'other' as the principal reason 40% of the time. 2. Flag any disparate-impact table HMDA data-quality manager cannot explain from geographic application and origination heat map. 3. Test a documented exception versus a pattern a credit union rolling out a special-purpose credit program must defend. 4. For this Fair Lending CRA and Special-Purpose Programs file, read geographic application and origination heat map against a notice that cites 'other' as the principal reason 40% of the time 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 (geographic application and origination heat map after a notice that cites 'other' as the principal reason 40% of the time). The follow-on CRA and Special-Purpose Programs action is what HMDA data-quality manager does next: implement the option, assign an owner, and log the missing fact.