Assess whether the exam response should concede a finding from small-business

SITUATION HMDA data-quality manager is responsible for the exam response should in a lender expanding into majority-minority census tracts, using small-business decline comparative file set as the only working extract. A HMDA resubmission that still fails quality edits is what reset the timeline for this Fair Lending Pricing and Credit Limits file.

DECISION HMDA data-quality manager in a lender expanding into majority-minority census tracts 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 HMDA resubmission that still fails quality edits.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; small-business decline comparative file set already has the discriminator after a HMDA resubmission that still fails quality edits. 2. Keep Temporary compensating control in force until small-business decline comparative file set is completed after a HMDA resubmission that still fails quality edits for HMDA data-quality manager. 3. Treat small-business decline comparative file set as Approve a documented exception because both readings appear after a HMDA resubmission that still fails quality edits. 4. Refuse a Fair Lending close: HMDA data-quality manager does not have the decision the exam response should turns on in small-business decline comparative file set.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in small-business decline comparative file set. 2. Check HMDA coding and underwriting policy against the exam response should. 3. Compare small-business decline comparative file set to similarly situated files, second-review notes, and reason codes after a HMDA resubmission that still fails quality edits. 4. For this Fair Lending Pricing and Credit Limits file, read small-business decline comparative file set against a HMDA resubmission that still fails quality edits and write the one fact that would move the exam response should for HMDA data-quality manager.

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 HMDA resubmission that still fails quality edits). If small-business decline comparative file set cannot force a Fair Lending label under Pricing and Credit Limits, stop. If small-business decline comparative file set after a HMDA resubmission that still fails quality edits cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending Pricing and Credit Limits close, HMDA data-quality manager must do not infer a control or scheme beyond the transaction and entitlement evidence.