Community-development lender must resolve whether the exam response should

Situation

Small-business decline comparative file set arrived with a DOJ or CFPB monitor request for pricing files for community-development lender. That is a Fair Lending Pricing and Credit Limits decision on the exam response should in a bank with thin HMDA LAR quality.

Decision

Community-development lender 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 small-business decline comparative file set after a DOJ or CFPB monitor request for pricing files.

Hypotheses to test

• The population in small-business decline comparative file set is the one a DOJ or CFPB monitor request for pricing files named, so Remove access or reverse the item follows for this Pricing and Credit Limits file.
• The population in small-business decline comparative file set is adjacent only to a DOJ or CFPB monitor request for pricing files; Temporary compensating control is the honest Fair Lending call.
• A bank with thin HMDA LAR quality already contained a DOJ or CFPB monitor request for pricing files before small-business decline comparative file set arrived; no new Pricing and Credit Limits path.
• Provenance on small-business decline comparative file set after a DOJ or CFPB monitor request for pricing files is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Flag any disparate-impact table community-development lender cannot explain from small-business decline comparative file set.
• Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend.
• Match the adverse-action language to the facts in small-business decline comparative file set.
• For this Fair Lending Pricing and Credit Limits file, read small-business decline comparative file set against a DOJ or CFPB monitor request for pricing files 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 / Pricing and Credit Limits packet (small-business decline comparative file set after a DOJ or CFPB monitor request for pricing files). Lead with the Fair Lending option small-business decline comparative file set can support after a DOJ or CFPB monitor request for pricing files, then the two facts that force it, then the Monday action for community-development lender in a bank with thin HMDA LAR quality.