Assess whether notices match the actual decisioning reasons (ebc9be)

SITUATION Adverse-action notice principal-reason sample arrived with a branch that stopped taking applications in one ZIP for HMDA data-quality manager. That is a Fair Lending CRA and Special-Purpose Programs decision on notices match the actual in a credit union rolling out a special-purpose credit program.

DECISION HMDA data-quality manager in a credit union rolling out a special-purpose credit program must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using adverse-action notice principal-reason sample after a branch that stopped taking applications in one ZIP.

HYPOTHESES TO TEST 1. HMDA data-quality manager can defend Remove access or reverse the item from adverse-action notice principal-reason sample after a branch that stopped taking applications in one ZIP in a Fair Lending challenge. 2. HMDA data-quality manager cannot defend Remove access or reverse the item from adverse-action notice principal-reason sample; Temporary compensating control is what the extract actually supports after a branch that stopped taking applications in one ZIP. 3. A branch that stopped taking applications in one ZIP never reached the population in adverse-action notice principal-reason sample — reopen intake, do not close notices match the actual. 4. Two facts in adverse-action notice principal-reason sample after a branch that stopped taking applications in one ZIP conflict for HMDA data-quality manager; hold this CRA and Special-Purpose Programs file.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern a credit union rolling out a special-purpose credit program must defend. 2. Match the adverse-action language to the facts in adverse-action notice principal-reason sample. 3. Check HMDA coding and underwriting policy against notices match the actual. 4. For this Fair Lending CRA and Special-Purpose Programs file, read adverse-action notice principal-reason sample against a branch that stopped taking applications in one ZIP and write the one fact that would move notices match the actual 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 / CRA and Special-Purpose Programs packet (adverse-action notice principal-reason sample after a branch that stopped taking applications in one ZIP). The follow-on CRA and Special-Purpose Programs action is what HMDA data-quality manager does next: implement the option, assign an owner, and log the missing fact.

COMMAND RETURNS - Bottom-line Fair Lending option on notices match the actual, then the evidence in adverse-action notice principal-reason sample, then the action for HMDA data-quality manager - Hypothesis scorecard against adverse-action notice principal-reason sample: supported / rejected / untestable - Regulatory or exam hook CRA and Special-Purpose Programs would cite - CRA and Special-Purpose Programs finding in adverse-action notice principal-reason sample that a second reviewer can re-perform