Assess whether the exam response should concede a finding (7ed8a2)

SITUATION In an institution preparing for a redlining exam, HMDA LAR validity and quality edits is the evidence after a HMDA resubmission that still fails quality edits. CRA strategist has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending Redlining and HMDA Data close using HMDA LAR validity and quality edits.

DECISION CRA strategist in an institution preparing for a redlining exam 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 HMDA resubmission that still fails quality edits.

HYPOTHESES TO TEST 1. HMDA LAR validity and quality edits reads as Remove access or reverse the item once a HMDA resubmission that still fails quality edits is lined up to the same Fair Lending population. 2. HMDA LAR validity and quality edits is closer to Temporary compensating control after a HMDA resubmission that still fails quality edits; Remove access or reverse the item would over-claim this Redlining and HMDA Data extract. 3. Approve a documented exception is still live in HMDA LAR validity and quality edits for CRA strategist in an institution preparing for a redlining exam. 4. HMDA LAR validity and quality edits is missing the fact CRA strategist needs after a HMDA resubmission that still fails quality edits; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern an institution preparing for a redlining exam must defend. 2. Match the adverse-action language to the facts in HMDA LAR validity and quality edits. 3. Check HMDA coding and underwriting policy against the exam response should. 4. For this Fair Lending Redlining and HMDA Data file, read HMDA LAR validity and quality edits against a HMDA resubmission that still fails quality edits and write the one fact that would move the exam response should for CRA strategist.

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 (HMDA LAR validity and quality edits after a HMDA resubmission that still fails quality edits). The follow-on Redlining and HMDA Data action is what CRA strategist 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 HMDA LAR validity and quality edits, then the action for CRA strategist - Hypothesis scorecard against HMDA LAR validity and quality edits: supported / rejected / untestable - Missing page in HMDA LAR validity and quality edits after a HMDA resubmission that still fails quality edits, if any - Regulatory or exam hook Redlining and HMDA Data would cite