Assess whether the exam response should concede a finding (31b36c)

SITUATION HMDA LAR validity and quality edits arrived with a branch that stopped taking applications in one ZIP for HMDA data-quality manager. That is a Fair Lending CRA and Special-Purpose Programs decision on the exam response should in a credit union rolling out a special-purpose credit program.

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 HMDA LAR validity and quality edits after a branch that stopped taking applications in one ZIP.

HYPOTHESES TO TEST 1. HMDA data-quality manager can defend Remove access or reverse the item from HMDA LAR validity and quality edits after a branch that stopped taking applications in one ZIP in a Fair Lending challenge. 2. HMDA data-quality manager cannot defend Remove access or reverse the item from HMDA LAR validity and quality edits; 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 HMDA LAR validity and quality edits — reopen intake, do not close the exam response should. 4. Two facts in HMDA LAR validity and quality edits after a branch that stopped taking applications in one ZIP conflict for HMDA data-quality manager; hold this CRA and Special-Purpose Programs file.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in HMDA LAR validity and quality edits. 2. Check HMDA coding and underwriting policy against the exam response should. 3. Compare HMDA LAR validity and quality edits to similarly situated files, second-review notes, and reason codes after a branch that stopped taking applications in one ZIP. 4. For this Fair Lending CRA and Special-Purpose Programs file, read HMDA LAR validity and quality edits against a branch that stopped taking applications in one ZIP 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 (HMDA LAR validity and quality edits after a branch that stopped taking applications in one ZIP). Lead with the Fair Lending option HMDA LAR validity and quality edits can support after a branch that stopped taking applications in one ZIP, 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.

COMMAND RETURNS - Bottom-line Fair Lending option on the exam response should, then the evidence in HMDA LAR validity and quality edits, then the action for HMDA data-quality manager - Hypothesis scorecard against HMDA LAR validity and quality edits: supported / rejected / untestable - Regulatory or exam hook CRA and Special-Purpose Programs would cite - CRA and Special-Purpose Programs finding in HMDA LAR validity and quality edits that a second reviewer can re-perform