Assess whether the exam response should concede a finding (f5c958)

SITUATION A live Fair Lending Examination and Notices file in a credit union rolling out a special-purpose credit program now turns on small-business decline comparative file set after a board asking if the bank should settle a matched-pair study. Second-review underwriter should state what that extract proves for whether the exam response should concede a finding.

DECISION Second-review underwriter 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 small-business decline comparative file set after a board asking if the bank should settle a matched-pair study.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; small-business decline comparative file set already has the discriminator after a board asking if the bank should settle a matched-pair study. 2. Keep Temporary compensating control in force until small-business decline comparative file set is completed after a board asking if the bank should settle a matched-pair study for second-review underwriter. 3. Treat small-business decline comparative file set as Approve a documented exception because both readings appear after a board asking if the bank should settle a matched-pair study. 4. Refuse a Fair Lending close: second-review underwriter does not have the decision the exam response should turns on in small-business decline comparative file set.

ANALYSIS REQUIRED 1. Compare small-business decline comparative file set to similarly situated files, second-review notes, and reason codes after a board asking if the bank should settle a matched-pair study. 2. Flag any disparate-impact table second-review underwriter cannot explain from small-business decline comparative file set. 3. Test a documented exception versus a pattern a credit union rolling out a special-purpose credit program must defend. 4. For this Fair Lending Examination and Notices file, read small-business decline comparative file set against a board asking if the bank should settle a matched-pair study and write the one fact that would move the exam response should for second-review underwriter.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Examination and Notices packet (small-business decline comparative file set after a board asking if the bank should settle a matched-pair study). Lead with the Fair Lending option small-business decline comparative file set can support after a board asking if the bank should settle a matched-pair study, then the two facts that force it, then the Monday action for second-review underwriter in a credit union rolling out a special-purpose credit program.