Assess whether the exam response should concede a finding (a96d95)

SITUATION Underwriting exception log by branch arrived with a marketing mailer that skipped majority-minority tracts. HMDA data-quality manager in a small-business desk using a new vendor score still has an evidence gap on whether the exam response should concede a finding.

DECISION HMDA data-quality manager in a small-business desk using a new vendor score must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using underwriting exception log by branch after a marketing mailer that skipped majority-minority tracts.

HYPOTHESES TO TEST 1. A marketing mailer that skipped majority-minority tracts is noise around an already-controlled Examination and Notices process in a small-business desk using a new vendor score, given underwriting exception log by branch. 2. A marketing mailer that skipped majority-minority tracts is the event in underwriting exception log by branch that forces Remove access or reverse the item for HMDA data-quality manager under Fair Lending. 3. Underwriting exception log by branch shows a one-file miss after a marketing mailer that skipped majority-minority tracts, not a Examination and Notices program failure. 4. Underwriting exception log by branch cannot decide the exam response should yet after a marketing mailer that skipped majority-minority tracts; hold is the only Fair Lending close a small-business desk using a new vendor score can defend.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against the exam response should. 2. Compare underwriting exception log by branch to similarly situated files, second-review notes, and reason codes after a marketing mailer that skipped majority-minority tracts. 3. Flag any disparate-impact table HMDA data-quality manager cannot explain from underwriting exception log by branch. 4. For this Fair Lending Examination and Notices file, read underwriting exception log by branch against a marketing mailer that skipped majority-minority tracts 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 / Examination and Notices packet (underwriting exception log by branch after a marketing mailer that skipped majority-minority tracts). Lead with the Fair Lending option underwriting exception log by branch can support after a marketing mailer that skipped majority-minority tracts, then the two facts that force it, then the Monday action for HMDA data-quality manager in a small-business desk using a new vendor score.

COMMAND RETURNS - Bottom-line Fair Lending option on the exam response should, then the evidence in underwriting exception log by branch, then the action for HMDA data-quality manager - Hypothesis scorecard against underwriting exception log by branch: supported / rejected / untestable - What changes the exam response should if a marketing mailer that skipped majority-minority tracts is later withdrawn - Named option among Remove access or reverse the item, Temporary compensating control, Approve a documented exception and the fact that kills the others