Assess whether the exam response should concede a finding (e55e6d)

SITUATION An institution preparing for a redlining exam cannot treat a HMDA resubmission that still fails quality edits as incidental context on underwriting exception log by branch. Community-development lender must close the exam response should from that extract under Fair Lending / CRA and Special-Purpose Programs.

DECISION Community-development lender 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 underwriting exception log by branch after a HMDA resubmission that still fails quality edits.

HYPOTHESES TO TEST 1. Community-development lender can defend Remove access or reverse the item from underwriting exception log by branch after a HMDA resubmission that still fails quality edits in a Fair Lending challenge. 2. Community-development lender cannot defend Remove access or reverse the item from underwriting exception log by branch; Temporary compensating control is what the extract actually supports after a HMDA resubmission that still fails quality edits. 3. A HMDA resubmission that still fails quality edits never reached the population in underwriting exception log by branch — reopen intake, do not close the exam response should. 4. Two facts in underwriting exception log by branch after a HMDA resubmission that still fails quality edits conflict for community-development lender; hold this CRA and Special-Purpose Programs file.

ANALYSIS REQUIRED 1. Compare underwriting exception log by branch to similarly situated files, second-review notes, and reason codes after a HMDA resubmission that still fails quality edits. 2. Flag any disparate-impact table community-development lender cannot explain from underwriting exception log by branch. 3. Test a documented exception versus a pattern an institution preparing for a redlining exam must defend. 4. For this Fair Lending CRA and Special-Purpose Programs file, read underwriting exception log by branch against a HMDA resubmission that still fails quality edits 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 / CRA and Special-Purpose Programs packet (underwriting exception log by branch after a HMDA resubmission that still fails quality edits). Lead with the Fair Lending option underwriting exception log by branch can support after a HMDA resubmission that still fails quality edits, then the two facts that force it, then the Monday action for community-development lender in an institution preparing for a redlining exam.