Assess whether the exam response should concede a finding (8600ce)

SITUATION In a bank with thin HMDA LAR quality, mortgage pricing residual by prohibited-basis group is the evidence after a marketing mailer that skipped majority-minority tracts. CRA strategist has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending Examination and Notices close using mortgage pricing residual by prohibited-basis group.

DECISION CRA strategist 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 mortgage pricing residual by prohibited-basis group after a marketing mailer that skipped majority-minority tracts.

HYPOTHESES TO TEST 1. The population in mortgage pricing residual by prohibited-basis group is the one a marketing mailer that skipped majority-minority tracts named, so Remove access or reverse the item follows for this Examination and Notices file. 2. The population in mortgage pricing residual by prohibited-basis group is adjacent only to a marketing mailer that skipped majority-minority tracts; Temporary compensating control is the honest Fair Lending call. 3. A bank with thin HMDA LAR quality already contained a marketing mailer that skipped majority-minority tracts before mortgage pricing residual by prohibited-basis group arrived; no new Examination and Notices path. 4. Provenance on mortgage pricing residual by prohibited-basis group after a marketing mailer that skipped majority-minority tracts is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

ANALYSIS REQUIRED 1. Compare mortgage pricing residual by prohibited-basis group to similarly situated files, second-review notes, and reason codes after a marketing mailer that skipped majority-minority tracts. 2. Flag any disparate-impact table CRA strategist cannot explain from mortgage pricing residual by prohibited-basis group. 3. Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend. 4. For this Fair Lending Examination and Notices file, read mortgage pricing residual by prohibited-basis group against a marketing mailer that skipped majority-minority tracts 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 / Examination and Notices packet (mortgage pricing residual by prohibited-basis group after a marketing mailer that skipped majority-minority tracts). The follow-on Examination and Notices action is what CRA strategist does next: implement the option, assign an owner, and log the missing fact.