Assess whether the exam response should concede a finding (642fc7)

SITUATION Community-development lender is responsible for the exam response should in a mortgage company after a pricing-regression spike, using small-business decline comparative file set as the only working extract. An exception rate twice as high for one group after credit controls is what reset the timeline for this Fair Lending Redlining and HMDA Data file.

DECISION Community-development lender in a mortgage company after a pricing-regression spike must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using small-business decline comparative file set after an exception rate twice as high for one group after credit controls.

HYPOTHESES TO TEST 1. An exception rate twice as high for one group after credit controls is noise around an already-controlled Redlining and HMDA Data process in a mortgage company after a pricing-regression spike, given small-business decline comparative file set. 2. An exception rate twice as high for one group after credit controls is the event in small-business decline comparative file set that forces Remove access or reverse the item for community-development lender under Fair Lending. 3. Small-business decline comparative file set shows a one-file miss after an exception rate twice as high for one group after credit controls, not a Redlining and HMDA Data program failure. 4. Small-business decline comparative file set cannot decide the exam response should yet after an exception rate twice as high for one group after credit controls; hold is the only Fair Lending close a mortgage company after a pricing-regression spike can defend.

ANALYSIS REQUIRED 1. Flag any disparate-impact table community-development lender cannot explain from small-business decline comparative file set. 2. Test a documented exception versus a pattern a mortgage company after a pricing-regression spike must defend. 3. Match the adverse-action language to the facts in small-business decline comparative file set. 4. For this Fair Lending Redlining and HMDA Data file, read small-business decline comparative file set against an exception rate twice as high for one group after credit controls and write the one fact that would move the exam response should for community-development lender.

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 (small-business decline comparative file set after an exception rate twice as high for one group after credit controls). The follow-on Redlining and HMDA Data action is what community-development lender does next: implement the option, assign an owner, and log the missing fact.