Assess whether the exam response should concede a finding (13d002)

SITUATION Adverse-action notice operations lead is responsible for the exam response should in a lender expanding into majority-minority census tracts, using manufactured-housing dealer overlay notes as the only working extract. A branch that stopped taking applications in one ZIP is what reset the timeline for this Fair Lending Redlining and HMDA Data file.

DECISION Adverse-action notice operations lead in a lender expanding into majority-minority census tracts must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using manufactured-housing dealer overlay notes after a branch that stopped taking applications in one ZIP.

HYPOTHESES TO TEST 1. Manufactured-housing dealer overlay notes reads as Remove access or reverse the item once a branch that stopped taking applications in one ZIP is lined up to the same Fair Lending population. 2. Manufactured-housing dealer overlay notes is closer to Temporary compensating control after a branch that stopped taking applications in one ZIP; Remove access or reverse the item would over-claim this Redlining and HMDA Data extract. 3. Approve a documented exception is still live in manufactured-housing dealer overlay notes for adverse-action notice operations lead in a lender expanding into majority-minority census tracts. 4. Manufactured-housing dealer overlay notes is missing the fact adverse-action notice operations lead needs after a branch that stopped taking applications in one ZIP; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against the exam response should. 2. Compare manufactured-housing dealer overlay notes to similarly situated files, second-review notes, and reason codes after a branch that stopped taking applications in one ZIP. 3. Flag any disparate-impact table adverse-action notice operations lead cannot explain from manufactured-housing dealer overlay notes. 4. For this Fair Lending Redlining and HMDA Data file, read manufactured-housing dealer overlay notes against a branch that stopped taking applications in one ZIP and write the one fact that would move the exam response should for adverse-action notice operations lead.

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 (manufactured-housing dealer overlay notes after a branch that stopped taking applications in one ZIP). Lead with the Fair Lending option manufactured-housing dealer overlay notes can support after a branch that stopped taking applications in one ZIP, then the two facts that force it, then the Monday action for adverse-action notice operations lead in a lender expanding into majority-minority census tracts.