Assess whether the exam response should concede a finding (10e5fc)

SITUATION After a CRA PE that called the assessment area too narrow, small-business decline comparative file set is what CRA strategist can touch in an institution preparing for a redlining exam. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this Redlining and HMDA Data file.

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 small-business decline comparative file set after a CRA PE that called the assessment area too narrow.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; small-business decline comparative file set already has the discriminator after a CRA PE that called the assessment area too narrow. 2. Keep Temporary compensating control in force until small-business decline comparative file set is completed after a CRA PE that called the assessment area too narrow for CRA strategist. 3. Treat small-business decline comparative file set as Approve a documented exception because both readings appear after a CRA PE that called the assessment area too narrow. 4. Refuse a Fair Lending close: CRA strategist does not have the decision the exam response should turns on in small-business decline comparative file set.

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 small-business decline comparative file set. 3. Check HMDA coding and underwriting policy against the exam response should. 4. For this Fair Lending Redlining and HMDA Data file, read small-business decline comparative file set against a CRA PE that called the assessment area too narrow 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 (small-business decline comparative file set after a CRA PE that called the assessment area too narrow). 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 small-business decline comparative file set, then the action for CRA strategist - Hypothesis scorecard against small-business decline comparative file set: supported / rejected / untestable - Regulatory or exam hook Redlining and HMDA Data would cite - Redlining and HMDA Data finding in small-business decline comparative file set that a second reviewer can re-perform