Assess whether notices match the actual decisioning reasons (d6bef1)

SITUATION The working file is CRA assessment-area versus lending footprint after a branch that stopped taking applications in one ZIP. Fair-lending officer in a bank with thin HMDA LAR quality has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending CRA and Special-Purpose Programs file.

DECISION Fair-lending officer 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 CRA assessment-area versus lending footprint after a branch that stopped taking applications in one ZIP.

HYPOTHESES TO TEST 1. A branch that stopped taking applications in one ZIP is noise around an already-controlled CRA and Special-Purpose Programs process in a bank with thin HMDA LAR quality, given CRA assessment-area versus lending footprint. 2. A branch that stopped taking applications in one ZIP is the event in CRA assessment-area versus lending footprint that forces Remove access or reverse the item for fair-lending officer under Fair Lending. 3. CRA assessment-area versus lending footprint shows a one-file miss after a branch that stopped taking applications in one ZIP, not a CRA and Special-Purpose Programs program failure. 4. CRA assessment-area versus lending footprint cannot decide notices match the actual yet after a branch that stopped taking applications in one ZIP; hold is the only Fair Lending close a bank with thin HMDA LAR quality can defend.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in CRA assessment-area versus lending footprint. 2. Check HMDA coding and underwriting policy against notices match the actual. 3. Compare CRA assessment-area versus lending footprint to similarly situated files, second-review notes, and reason codes after a branch that stopped taking applications in one ZIP. 4. For this Fair Lending CRA and Special-Purpose Programs file, read CRA assessment-area versus lending footprint against a branch that stopped taking applications in one ZIP and write the one fact that would move notices match the actual for fair-lending officer.

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 (CRA assessment-area versus lending footprint after a branch that stopped taking applications in one ZIP). The follow-on CRA and Special-Purpose Programs action is what fair-lending officer 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 CRA assessment-area versus lending footprint, then the action for fair-lending officer - Hypothesis scorecard against CRA assessment-area versus lending footprint: supported / rejected / untestable - CRA and Special-Purpose Programs finding in CRA assessment-area versus lending footprint that a second reviewer can re-perform - Missing page in CRA assessment-area versus lending footprint after a branch that stopped taking applications in one ZIP, if any